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HomeMy WebLinkAbout04-0045PETITION FOR PROBATE and GRANT OF LETTERS Estate of'~"~c/~Cl ~- ~,,L.~lCv~tV£}l also known as . . o.~Deceased. Social Security No. ~ & 9 3 ~_ - ~ The petition of the undersigned respectfully represents that: Your petitioner(s), who is/are 18 years of ag$or older an the execut in the last wilt of the above decedent, dated ..3 ~ and codicil(s) dated To: Register of Wills for the County of Commonwealth of Pennsylvania in the named , ~9' ~.--~ (state relevant circumstances, e.g. renunciation, death of executor, etc.) Decendent was domiciled at death in C c. v~x ~a,~ xL. LdA ~x 9 County, Pennsylvania, with h x~ last family or principal residence at ~ %~ C~ ~e D. eq~ _ (list street, number and muncipality) D~endeqt, then 6 Z-_ years of age, d~ed ~ ~ ~ ~ , ~ ~ % ~ , at E~p~as~l~o~ ~d~cedJ~ ~t marr~s ~no~fc~d~a~; ~d not have a child born or adopted after execution of the will offered for probate; was not the victim of a killing and was never adjudicated incompetent: Decendent at death owned property with estimated values as follows: (If domiciled in Pa.) All personal property $ (If not domiciled in Pa.) Personal property in Pennsylvania $ (If not domiciled in Pa.) Personal property in County $ Value of real estate in Pennsylvania $ situated as follows: WHEREFORE, petitioner(s) respectfully ye~q.uest(s) the probate of the last will and codicil(s) presented herewith and the grant of letters '/-e~-V,A xw,.e.~,~'-~%~.£ ,~ theron. (testamentary; administration c.t.a.; administration d.b.n.c.t.a.) OATH OF' PERSONAL REPRESENTATIVE COMMONWF~kLTH OF PENNSYLVANIA 3 COUNTY OFf ~s The petitioner(s) above-named swear(s) or affirm(s) that the statements in the foregoing petition are true and correct to the best of the knowledge and belief of petitioner(s) and that as personal represen- tative(s) of the above decedent petitioner(s) will well and truly administer the estate according to law. Sworn to or affirmed and subscribed c (~~~r~'7'Q~;~/~L~.~ ~)gre me this //_~/7''~/ day of /d ~' Estate Of DECREE OF PROBATE AND GRANT OF LETTERS , Deceased AND NOW the reverse side hereof, satisfactory proof having been p/~e. nted before me, IT IS DECREED that the instrument(s) dated described therein be admitted to probatq azjA~filed of recffrd as the last (~ill of and Letters ~_e~ .~-~/".o~,~,,~,-~.~,' , ark hereby gr~anted to ~~_z/~//~c~'~-~z/~_.~ / I~>-~ , in consideration of the petition on FEES Probate, Letters, Etc .......... Short Certificates( ) .......... tion ................ / TOTAL rile~aa~e, dd... ATTORNEY (Sup. Ct. I.D. No.) PHONE his is to certify that the information here given is correctly copied from an original certificate of death duly filed with me as Local Registrar. The original certificate will be forwarded to the State Vital Records Office for permanent filing. WARNING: It is illegal to duplicate this copy by photostat or photograph. Fee for this certificate, $2.00 ~ ~ ./~ ~~~ ~ Local Registra~- - P S 81 3,5 5 1 JAN I B 2004 No. '~ Date 05.143 Rev. 2/87 COMMONWEALTH OF PENNSYLVANIA · DEPARTMENT OF HEALTH · VITAL RECORDS CERTIFICATE OF DEATH STATE FILE NUMBER "Z DY IF;L .W'.' i'?' Isex . SECUR,..UMBER OF Dm. ( th. D". ~ -~ -. ~en 12~ I~ 18o ~ u~v~ I . . ~. ' ' ' I ' 7 -- ~ -- ~ 14.I--~-U~ ' AGE(~B~By) J UNDER1Y~ I UNDERI~6Y DATE~BIR~ I BR~P~CE(~B~ IP~CEOFD~k~-s~s~u~ii ' ~n~II Da~ "~I ~* (~n. Day. Y"*)II s~th ~ F~. ~) I~:~ ~ ~ I OmER- COU~OF D~,'' I _ I ' . I · [ ' I ~ U - '~ '~ (~) U ~fn [ Cl~, B~O, ~ OF D~TH [ FACILI~ ~ME (if ~t i~titu~n, give ~.t a~ numar)[W~ DECEDENT OF HISP~IC ORIGIN? ]~CE- ~ In~ B~d C~ . . ' . No~ yes If ~., ~ C~, (~) ' DECEDENUS USUAL ~CUPATI~ ' I ~, I 10. DECEDENTS E~TI~ SURV~ING ~OUSE KIND OF BUSINESS I INDUSTRY ~AS DECEDENT ~ER iNI I ~IT~ STA~S - M.,C~ ~ (e~~ I U.S. ~MED FORCES? (Sp~o~~) I ~,~, ' DECEDENTS ~IMNG ADD.SS {S~e(, ~, S~le, ~ ~) ~ DECEDENTS FATHER'S NAME (Fk~, M~.~_~. Last) t.. I/4,tfl~ Pu~b. wt4ch, ~. I~S ~E METH~ ~ DI~ITI~ DATE ~ DIS~SITION SIGNORE ~.F~NE~SERVlCE L~ENSEE OR PERSON ACTING AS SUCH I LICENSE NUMBER ?e~ 2~ ~ ~ I To ne ~*t o~ mY ~d~, deem .... d at,he ~ dele a~ pl~e smt~ ~?~ ~--;~ by I TIME OF D~TH DATE ~ONOU~ED "~O (~. Day JMOTHER'S NAME (Flint, Middle, Maidegl Surname) ~Ob. C, p~ vx,~ve, Hee~o~g, PA 17055 21c. PA ~xq ' -I'd. H~6b~Rt PA N~E ~D ADDRESS OF F~ILI~ ~0~ SO~ 04 17109 17109 ILICENSE NUMBER DATE SIGNED I (Month, Day, Year) 25b. 123c. WAS CASE ~I:I-I-RRED TO A MEDICAL ~XAMINER/CORONER? .. Y" El ~'Y/W .o [] . .A4?pmxi. male PART #: Other significant conditionl cont~buUng to dee. but IMMEDIATE CAUSE (Final disease or com~Alon rseu~t~no th death) ~ a. ~equenUally list co~dit~ns b. cause. Entre UNDERLYING CAUSE (Disease o~ injury that in#leted even~ ~sultthg on death ) LAST DUE TO (OR AS A CONSEQUENCE DF): -" onae~ and death WAS AN AUTOPSYWERE AUTOPSY FINDINGS ]MANNER OF DEATH I DATE OF INJURY I TIME OF INJURY PERFORMED? AVAILABLE PRIOR TO ~II~.. Day. Year) I COMPLETION OF CAUSEI Natural~ Homicide OF DEATH? ~ Accident [] Pending Invesdgatinn YesF--I N°I7] YesD NOI71] ISuiOide [] Couldnolbedelermined [] ~a'~l~ [30b.____ M* [ PLACE OF INJURY - At home, farm. street, lactory, office 28.. 28b. L J 30ebbing.. ~tc. (Speciy) 'PRONOUNCING AND CERTIFYING PNY$1ClAN (Physician both pronouncing death anil Celt!lying Io cause of death) 'MEDICAL EXAMINER/CORONER 31 e.ma~rmr l~ llatod ............................................................................................................................................ [] ,,. REGISTRAR'S $IGNATURE AND NUMBER ~ ~ ~ 14/'4/r'1 no~ restdtthg in the undedying cause given bi PART I. INJURY AT WORK? I DESCRIBE HOW INJURY OCCURRED. LICEl~$1~J~l~4S~a~. __~.. · D~kTE~IGNEO (Month Day Year) (I~27)T~P~l ~ ~ /~7~ DATE FILED (Month, Day, Year) //- LAST WILL AND TESTAMENT OF VIRGIL F. PUSKARICH I, VIRGIL F. PUSKARICH, of Cumberland County, Pennsylvania, declare this to be my Last Will and revoke any Will previously made by me. ITEM ONE I direct that my remains be cremated and the arrangements be made with the Cremation Society of Pennsylvania. ITEM TWO I direct that all my just debts, expenses of my last illness, and funeral expenses shall be paid from the assets of my estate, as soon as practical after my decease, as a part of the administration of my estate. ITEM THREE I bequest any and all motor vehicles and their accessories and equipment, all personal effects and belongings, all jewelry, clothing and other articles of household use or ornament and all other tangible personalty of like nature (not including cash and securities), and all insurance policies relating to such property, owned by me at the time of my death to my wife, MARILYN PUSKARICH, if she survives me for a period of thirty (30) days. If she predeceases me, I give my said personal property and the insurance thereon to my then living children to be divided among them as they agree. If they cannot agree, then the said personal property shall be sold and the proceeds distributed to them in equal shares. 1 ITEM FOUR Subject to the payments in Item Two, my Personal Representative shall distribute the net income and principal of all of the remainder of the residue of my estate, including without limitation, all property or interest therein acquired by me or to or which I may become entitled after the execution of this Will, and all property over which I shall have a power of appointment or disposal which I shall not have otherwise exercised, or refused to exercise, to the named Trustees to hold IN TRUST, as part of the Trust Estate of the VIRGIL F. PUSKARICH Family Trust Agreement dated th6~ day of January, 2003, as amended at any time prior to my death, or, if said Agreement is no longer in effect, to hold, IN TRUST, on the terms and conditions specified in said Agreement on the date of this Will or of the last Codicil hereto, which like effect as if they were set forth herein verbatim. ITEM FIVE If my wife, MARILYN PUSKARICH, shall die simultaneously with me or there is no sufficient evidence to establish that my wife and I died otherwise than simultaneously, I direct that I shall be presumed to have predeceased my wife, MARILYN PUSKARICH, notwithstanding any provision of the law to the contrary and that the provisions of my Will shall be construed on such presumption. ITEM SIX I authorize my Executor to claim administrative expenses as a deduction upon my estate return or upon an income tax return or returns as he or it in his or its discretion shall considered to be in the best interests of my beneficiaries, with no duty to make adjustments between income and principal as a result thereof. 2 ITEM SEVEN I direct that all estate, inheritance and other taxes in the nature thereof, together with any interest and penalties thereon, becoming payable because of my death with respect to the property constituting my gross estate for death tax purposes, whether or not such property passes under this Will, shall be paid from the principal of my residuary estate, and no person receiving or having a beneficial interest in any such property, whether under this Will or otherwise, shall at any time be required to contribute or to refund any part hereof, PROVIDED, however, that this direction shall not apply to taxes on my property included in my estate solely because ora power of appointment thereover which I possess but have not exercised or on any qualified terminable interest or to any generation skipping transfer. ITEM EIGHT All of my insurance policies which provide indemnity for the loss of any of my personal or real property by fire, windstorm or other similar casualty (including any claim for the loss against any insurance company), I give and bequest, respectively, to those persons or corporations, as the case may be, who shall become the owners of such properties by reason of my death, whether such ownership be acquired under the provisions of this Will, by survivorship or by other means. ITEM NINE Any and all payment or payments of any sum or sums, whether in cash or in kind and whether for principal or income, payable to the said beneficiaries of my estate shall be free from anticipation, assignment, pledge, or obligation of any beneficiary, and shall not be subject to any execution or attachment. 3 ITEM TEN I appoint my Wife, MARILYN PUSKARICH, Executor of this my last Will. Should my Wife, MARILYN L. PUSKARICH, fail to qualify or cease to act as Executor, I appoint my daughters, LYNN M. TOSH and LAURA M. PUSKARICH, Co- Executors of this my last Will. I appoint SUELLEN M. WOLFE, attorney of my estate. No bond shall be required of any fiduciary hereunder or in any jurisdiction. No fiduciary hereunder shall have any liability for any mistake or error of judgement made in good faith. ITEM ELEVEN My Personal Representative shall have the following powers in addition to those vested in them by law and by other provisions of my Will, applicable to all property, including property held for minors, whether principal or income, exercisable without court approval, and effective until actual distribution of all property. Such list of powers is not exclusive and it is not meant or intended for the powers hereinafter set forth to be exclusionary and in derogation of any remaining statutory powers; and To retain, any or all property owned by me at the time of my death in the form in which it then exists; acquire by purchase or otherwise or retain, temporarily or permanently, any kind of realty and personalty including stocks and unsecured obligations, undivided interest, interests in investment trusts, mutual funds, legal and discretionary common trust funds, leases, any property belonging to my estate, and property which is outside of my domicile, all without diversification as to kind or amount and without being limited to investments authorized by law for trust funds, (including the discretion to retain as an investment any obligation or obligations owing to me by any corporation in which I have a stock interest at the time of my death) and hold funds uninvested, or deposit any moneys in one or more savings or other banks in any form of account whether or not interest bearing; and To vote in person or by general, limited or discretionary proxy, with respect to any investments that may be owned by my estate or any trust, or consent to any purpose, in respect of any stocks or other securities; exercise or sell any rights of subscription or other right in respect thereof; and To hold two or more trusts or other funds in one or more consolidated funds, in which the separate trusts or funds shall have undivided interest; and To sell, exchange, or otherwise dispose of realty and personalty publicly or privately, wholly or partly on credit or for any consideration including stocks, bonds or other corporate obligations and grant options for the purpose, exchange or other disposition of any such property; and To pay general legacies, establish trusts, divide or distribute principal, in kind or in money, or partly in each, or by way of undivided interests, even if shares be composed differently; and To delegate discretionary powers to agents, remunerate them, and pay their expenses, employ and pay the compensation of accountants, custodians, legal and investment counsel; and To ra~v, assign, alter, extend, compromise, release with or without consideration, or submit to arbitration, obligations or claims, including taxes, held by or asserted against them or which affect estate or trust assets; and To hold property in the name of nominees; and To borrow money from themselves or others and pledge or mortgage any property, for the payment of taxes, debts, legacies or expenses or any other propose which in their opinion will facilitate the administration of my estate or any trust; and To manage, retain, improve, alter, subdivide, develop, dedicate to public use or lease real property or grant easements with respect thereto for periods to begin presently or in the future without regard to statutory restrictions on leasing and even though any such period may extend beyond the term of any trusts; and To consent to and participate in any plan for the liquidation, reorganization, consolidation or merger of any corporation and security of which is held; and To abandon, in any way, property which the determine not to be worth protecting; and In connection with the administration of my estate and of any fund hereunder, I direct that all corporate stock distributions in the stock of the distributing corporation ( except such distribution, whether described as stock dividends, stock splits or otherwise, paid in stock of the distributing corporation, where the number of shares of that class of stock distributed to shareholders of that class amounts to six (6%) percent or less than the outstanding number of shares of that class on the record date for such distribution), all rights to subscribe accruing on or in respect of any securities held hereunder, all capital gains distributions on shares of mutual funds, and all liquidating dividends shall be treated as principal; and all other cash or stock dividends accruing on or in respect of any such securities shall be treated as income; and To make loans out of the trusts to my Executors provided that such loans are made on adequate security and for an adequate interest; and To allocate any portion of my Generation Skipping Tax exemption under Section 2631 (a) of the Internal Revenue Code, or any similar exemption, exclusion or other benefit allowable under the law in force when I die, to any property as to which I am the transferor, within the meaning of Section 2652(a) of the Internal Revenue Code, including any property transferred during my life, to elect out of any deemed allocation or revoke any prior election out, and to exercise the special election provided in Section 2652(a)(3) of the Internal Revenue Code as to any part or all of the Marital Trust under my above mentioned trust; and Notwithstanding any of the other provisions of this Will and the grant of any power either by common law, statute or as set forth herein, the Trustees shall not possess or exercise any power, the possession of which could or would in any manner disqualify the portion of my estate so qualified for the purposes of or with respect to the marital deduction under the federal estate tax laws or under any law of any state which may grant a similar marital deduction and which has proper jurisdiction of my estate upon my death for estate or similar tax purposes; and To join my wife in making a joint income tax or gift tax return or to execute a consent to any gift made by my wife for any fiscal year that included the date of my death or for any period thereto, and in connection therewith, to pay such amounts of tax, interest and penalty as they may deem advisable, even though not attributable entirely to my income or gifts without requiring an indemnification agreement. IN WITNESS WHEREOF, I have signed, sealed, published and declared this to be my Last Will and Testament, consisting of eight pages plus the Acknowledgment and Affidavit, in the presence of the persons witnessing it at my request thi~ay of January, 2003. VIRGIL F.~PUSKARICH 7 The preceding instrument, consisting of this and seven other typewritten pages, each identified by the signature of the Testator, was on the date thereof signed, published and declared by VIRGIL F. PUSKARICH, the Testator herein, named, as and for his Last Will and Testament in the presence of us, who in his presence, at his request, and in the presence of each other have subscribed our names as witnesses hereto. Name Name Name Address Address Address 8 ACKNOWLEDGMENT AND AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DAUPHIN · SS; ,AND Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, being first duly sworn, do hereby declare to the undersigned authority that the Testator signed and executed the instrument as his Last Will and Testament and that he signed willingly, and that he executed it as his free and voluntary act for the purpose therein expressed, and that each of the witnesses, in the presence and hearing of the Testator, signed the Will as witness and to the best of his knowledge the Testator was at the time eighteen years of age or older, of sound mind and under no constraint or undue influence· Testate-~, ' ' - Witness Wi.,t.~ss Witness Subscribed, sworn to and acknowledg~ and subscribed and sworn to me · es, thi,~y Notary Public (SEAL) ~ *,~. '~,~ (SEAL) (SEAL) (SEAL) t t efo, re me by VIRGIL F/.PUSIC4.RICH, the Testator, of January, 2003. 9 Buchanan Ingersoll :! Samuel J. Goncz 412-562-1381 gonczsj~bipc.com April 27, 2004 One Oxford Centre 301 Grant Street, 20th Floor Pittsburgh, PA 15219 1410 T 412 562 8800 F 412 562 1041 www. t:)ucha naningerso]l.co m Register of Wills of Cumberland County Hanover & High Streets Carlisle, PA 17013 Re: Estate of Virgil F. Puskarich No. 00045 of 2004 Dear Sir or Madam: Enclosed is a Certification of Notice Under Rule 5.6(a) for the above-referenced estate. Please file the same in your records for this estate. Please date stamp the enclosed copy and return it to me in the enclosed self-addressed, stamped envelope. Please call me if you have any questions. Sincerely, Samuel J. Goncz SJG/dmr Enclosure cc: Marilyn Puskarich Suellen M. Wolfe, Trustee # 1544069-v 1 ;PGH l_General;GONCZ 1 Domestic Offices :: Pennsylvania :: New York :: Washington, DC :: Florida :: New Jersey :: Delaware :: California IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF VIRGIL F. PUSKARICH Date of Death: January 4, 2004 ) ORPHANS' COURT DIVISION ) ) No. 00045 of 2004 CERTIFICATION OF NOTICE UNDER RULE 5.6(a) To the Register: I certify that notice of estate administration required by Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on April 26, 2004. Nanl e: Marilyn Puskarich Suellen M. Wolfe Lynn M. Tosh Laura M. Puskarich Address: 2496 Cope Drive Mechanicsburg, PA 17055 4278 Wimbledon Drive Harrisburg, PA 17112 2215 Spring Run Drive Mechanicsburg, PA 15055 320 Charles Road Mechanicsburg, PA 17050 Notice has been given to all persons entitled thereto under Rule 5.6(a) except: No exceptions Date: April 26, 2004 Signature: Name: Address: Telephone: Capacity: Samuel J. Goncz, Esq. C'fd Buchanan Ingersol,[1, P.C. 301 Grant St, 2 .L~h. i~'1, Op~Oxfora .-~tr Pittsburgh, PA ~5~:19 ~! ':. (412)562-1381 ~ 1-"-] Personal Representati~Tg [5~] Counsel for Personal [~presentative #1537217-vl-Cert Re 5 6;PGHI_General;PERRI1 IN RE: ESTATE OF VIRGIL F. PUSKARICH, Deceased IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION 04-0045 ORPHANS COURT PETITION FOR APPOINTMENT OF GUARDIANS OF THE ESTATES OF MINORS AND TO APPROVE DISCLAIMERS BY GUARDIANS OF MINORS' CONTINGENT INTERESTS IN DECEDENT'S ESTATE AND TRUST Petitioners, Lynn M. Tosh and Laura M. Puskarich, by and through their attorneys, Buchanan Ingersoll PC, file this Petition for Appointment of Guardians of the Estates of Minors and to Approve Disclaimers by Guardians of Minors' Contingent Interests in Decedent's Estate and Trust, as follows: -. ~ "~' I. JURISDICTION AND VENUE ~ 1. Jurisdiction over this matter is proper and mandatory in the Orphans'-Gourt division of this Court of Common Pleas pursuant to 20 Pa. C.S.A. § 711(4) (adminiStration and distribution of minors' estates). 2. Venue is proper before this Court under 20 Pa. C.S.A. § 721 (2) (if guardianship proceedings are not yet instituted, venue is proper in county where court would have jurisdiction to appoint guardian of estate); see also 20 Pa. C.S.A. § § 5111 (a) (guardian of minor's estate may be appointed by court of county where minor resides), (b) (guardian of estate within Pennsylvania of minor residing outside of Pennsylvania may be appointed by court of county having jurisdiction of estate or trust from which minor's interest derived). II. NATURE OF PETITION AND AUTHORITY 3. Petitioners respectfully request: (i) their appointment as guardians of the estates of certain minor beneficiaries derived from the estate of the Decedent, Virgil F. Puskarich (the "Estate"), and his Virgil F. Puskafich Family Trust Agreement (referred to herein as the "Trust Agreement" and the trusts created thereunder referred to collectively herein as the "Trust"); and (ii) authorization from this Court for Petitioners, as such guardians, to disclaim said minor beneficiaries' contingent interests therein. Copies of the Decedent's Will and the Trust Agreement are attached to this Petition as Exhibits "A" and "B," respectively. 4. The parents of the minor beneficiaries consent to this Petition. Their consents are attached hereto as collectively Exhibit "C." 5. Pursuant to 20 Pa. C.S.A. § 5111, etseq., this Court possesses the power to appoint guardians of the estates of minors. 6. A guardian may disclaim the interest of a minor in a decedent's estate, but only after authorization by a Court of competent jurisdiction, upon a finding that the disclaimer is advisable and will not materially prejudice the rights of the minor or the minor's creditors. 20 Pa. C.S.A. § 6202. 7. On January 4, 2004, Virgil F. Puskarich (the "Decedent") died testate and domiciled in Cumberland County, Pennsylvania. The Decedent's Last Will, dated January 3, 2003, (the "Will"), was admitted to probate on January 16, 2004, in the Office of the Register of Wills of Cumberland County. Consistent with the Will, the Register issued Letters Testamentary to the Decedent's widow and wife of 35 years, Marilyn Puskarich ("Marilyn"), residing at 2496 Cope Drive, Mechanicsburg, Pennsylvania 17055, and to Suellen Wolfe, residing at 4278 Wimbledon Drive, Harrisburg, Pennsylvania 17112. -2- 8. Petitioners Lynn M. Tosh ("Lynn") and Laura M. Puskarich ("Laura") are the only children of Decedent and Marilyn. Both Petitioners are suijuris and domiciled in Cumberland County, Pennsylvania. 9. The Decedent's primary asset, valued at approximately $1.6 million, was his accrued benefit in his employee pension and deferred compensation plans (collectively, the "Pension"). The Decedent did not have a valid beneficiary designation for his Pension and so, according to the terms of the Pension, the proceeds thereof are payable to his Estate. 71 Pa. C.S.A. § 5709(c). 10. The Decedent's Will first provides for the payment of his debts, administration expenses and taxes, and for the distribution of his tangible personal property. Under Item Four of his Will, the Decedent's Will then bequeaths the residue of his Estate, which consists primarily of his Pension, to the Trust. 11. Without the relief sought by this Petition, the Decedent's Pension will pass to the Trust and trigger immediate federal income taxation in the amount of approximately $575,000. 12. To preserve the Pension for Madlyn and the rest of the family as the Decedent intended, Petitioners seek (i) the appointment of themselves as guardians of the estates of three minors having contingent interests in the Estate and Trust, as well as (ii) Court authorization for Petitioners, as such guardians, to disclaim such interests. 13. Such disclaimers, coupled with anticipated disclaimers by all of the other possible beneficiaries of the Trust (including Marilyn) and the intestate heirs of the Decedent's Estate (other than Marilyn), would leave Marilyn as the sole beneficiary of the Estate. Under applicable Treasury Regulations, Marilyn would then be permitted to roll over the Pension into -3- an Individual Retirement Account ("IRA") and, thus, defer income taxation thereon until withdrawals are made therefrom. 26 U.S.C.A. § 402(c) and Treas. Reg. § 1.402(c)-2. 14. A private letter ruling request has been submitted to the Internal Revenue Service confirming the federal income tax result of the proposed actions, and Petitioners anticipate that the Internal Revenue Service will issue a favorable ruling within the next few weeks. III. DECEDENT'S ESTATE PLAN 15. The Trust evidences the Decedent's intent to provide for Marilyn. Article I of the Trust provides for the creation of two trusts for the benefit of Marilyn, known as "Trust A" and "Trust B." The amount required to fund Trust B is equal to the maximum amount of taxable transfers that the Decedent could make free of federal estate tax using the applicable federal exclusion amount and permissible state death tax credit (approximately $1.5 million). The balance of the Trust property would fund Trust A. See Trust at Exhibit "A," p. 1-2. 16. Upon Marilyn's death, the remaining property of both Trust A and Trust B is distributable to the Decedent's then-living issue, per stirpes. If the Decedent has no issue then living, such property is distributable in equal shares to the Decedent's sister, Darlene Bohnak ("Darlene"), and Marilyn's sister, Pamela Godwin McMahon ("Pamela"), each of whom survived the Decedent. If either Darlene or Pamela is not then living, then such person's share would pass to her then-living issue, per stirpes. See Trust at Exhibit "A," p. 4. 17. A diagram of the potential beneficiaries of the Estate and Trust and their relationships to the Decedent is attached to this Petition at Exhibit "D." A list of such potential beneficiaries and their ages and addresses is attached to this Petition as Exhibit "E." IV. DISCLAIMERS OF INTERESTS IN TRUST 18. The necessary parties to a trust are the settlor, the trustee and the beneficiary. Patrick v. Smith, 2 Pa. Super. 113 (1896). Without each of these parties, a trust must fail. If an -4- express trust fails, then the trustee holds the trust property upon a resulting trust solely for the benefit of the transferor or, if the transferor is not living, his or her estate. See generally, Estate of Smith, 435 Pa. 258, 263,256 A.2d 130, 132 (1969) (resulting trust for decedent's estate arises when bequest to decedent's revocable trust fails); Restatement (Second) of Trusts, § 411. This is particularly true if, as in this instance, an owner of property transfers it in trust and the beneficiary disclaims the trust property, such that there is no valid beneficiary. Id. at § 36 cmt. d. Under such circumstances, the trustee of the resulting trust has no discretion to act and must pay over any trust property to the transferor or the transferor's estate, as the case may be. 19. Thus, if all of the Trust beneficiaries disclaim their interests in the Trust, then the bequest to the Trust will fail. Unless a decedent's will makes another disposition, a failed residuary bequest is instead distributable to the decedent's intestate heirs. In re Ritter's Estate, 81 Pa. D&C. 498, 501 (O.C. Phila. Co., 1952) ("Intestacy may result not merely from the testator's failure to make a will at all, or from his failure to dispose in his will of all of his estate, but also from his failure to make a legal and effectual disposition of either his entire estate or a portion of it."). In this instance, upon the failure of the residuary bequest to the Trust, the residue of the Estate would instead be distributed to the Decedent's intestate heirs. Marilyn and Petitioners Lynn and Laura each intend to disclaim their interests in 20. the Trust. 21. Pamela survived the Decedent and has four children, each of whom is an adult and survived the Decedent. As stated above, Pamela has a contingent interest in the Trust that vests only if neither Marilyn nor any of the Decedent's issue is living upon the death of the Decedent or the termination of the Trust, and if Pamela is herself living at such time. Pamela and each of her four children intend to disclaim their interests in the Trust. -5- 22. In addition to her four children, Pamela has one other issue, Miyabi Gaskell ("Miya"), age 9, who is the daughter of Pamela's son, Daniel Gaskell, and his wife Masayo. Daniel, Masayo and Miya Gaskell reside in Greenville, South Carolina. 23. Darlene died on January 11, 2004, one week after the Decedent's death, and was survived by two adult children, Cynthia Bohnak ("Cynthia") and David Bohnak ("David"). Darlene's Estate will disclaim its interest in the Trust. Cynthia and David's contingent interests vest only if none of the Puskarich beneficiaries of the Trust survive the Decedent. They have also indicated that they will disclaim their interests in the Trust. 24. All adult beneficiaries of the Trust -- Marilyn, the Decedent's children (Petitioners Lynn and Laura), Pamela, Pamela's children (Daniel, Theodore, Stephen and Michael), Darlene (through her estate), and Darlene's children (Cynthia and David) -- are willing to disclaim their interests therein pursuant to 20 Pa. C.S.A. § 6201 (beneficiary's right to disclaim). 25. A disclaimer relates back to the date of the decedent's death or to the date of the inter vivos transfer. 20 Pa. C.S.A. § 6205(a). Unless otherwise provided in the governing instrument, the disclaimant is treated as having predeceased the decedent, in the case of a transfer by will or intestacy, and before the date of an inter vivos transfer. 20 Pa. C.S.A. § 6204(b). 26. Following the disclaimers of the adult beneficiaries of the Trust, the only remaining Trust beneficiaries will be Lynn's living issue, Annabelle Tosh and Clara Tosh, both of whom are minors, and Pamela's only minor issue, Miya. Accordingly, the Trust will not fail unless Annabelle, Clara and Miya also disclaim their contingent remainder interests. -6- 27. Pennsylvania law expressly permits the guardian of a minor's estate to disclaim the minor's interest in property upon court approval. Specifically, 20 Pa. C.S.A. § 6202 provides: A disclaimer on behalf of... a minor.., may be made by... the guardian of his estate.., if, in each case the court having jurisdiction of the estate authorizes the disclaimer after finding that it is advisable and will not materially prejudice the rights of... the minor or his creditors .... 28. Annabelle and Clara reside in Cumberland County, Pennsylvania, with their parents, Lynn and Adam Tosh. Accordingly, this Court may appoint guardians of the estates of Annabelle and Clara. 20 Pa. C.S.A. § 511 l(a) CA guardian of the person or of the estate of a minor may be appointed by the court of the county in which the minor resides."). 29. Although Lynn cannot be appointed as sole guardian of her own children's estates, she can be appointed as a co-guardian with a non-parent. 20 Pa. C.S.A. § 5112(3). Accordingly, the appointment of Lynn and Laura as co-guardians of the estates of Annabelle and Clara is appropriate and permissible under Pennsylvania law. 30. Miya's contingent interest is derived from the estate of a Pennsylvania decedent. This Court may appoint guardians of the estate of Miya, who is a nonresident of Pennsylvania residing in Greenville, South Carolina, under 20 Pa. C.S.A. § 511 l(b), which provides: A guardian of the estate within the Commonwealth of a minor residing outside the Commonwealth may be appointed by the court of the county having jurisdiction of a decedent's estate or of a trust from which the minor's estate is derived. 31. Lynn and Laura are also qualified to serve as co-guardians of Miya's estate. 32. The interests of Annabelle and Clara in the Trust vest only if they survive their grandmother, Marilyn, and if their mother, Lynn, predeceases Marilyn. Because their interests -7- are so unlikely to vest, they should not be deemed material. Annabelle and Clara have no known creditors. 33. Miya's interest in the Trust vests only if Marilyn and all of the Decedent's issue die before the Trust termination and ifMiya's grandmother, Pamela, and her father, Daniel, are not then living. Thus, Miya's interest also should not be deemed material. Miya has no known creditors. 34. The disclaimers sought herein are advisable under all circumstances and do not materially prejudice the rights of the minors or the minors' creditors. V. DECEDENT'S INTESTATE BENEFICIARIES 35. As stated hereinabove, if the Trust fails for lack ora beneficiary, then the residuary bequest under the Decedent's Will also fails. Under such circumstances, the residue of the Estate passes to the Decedent's intestate heirs. See In re Ritter's Estate, 81 Pa. D&C. 498, 501 (O.C. Philadelphia Co., 1952). 36. The Decedent's intestate heirs consist of Madlyn and her two children, Lynn and Laura. See 20 Pa. C.S.A. § 2102 (share of surviving spouse), § 2103 (share of other than surviving spouse). 37. Lynn and Laura have indicated that they will disclaim their intestate rights in the Decedent's Estate. Because Laura has no issue, the entire intestate share not passing to Marilyn would then pass to Lynn's minor children, Annabelle and Clara. See 20 Pa. C.S.A. § 2104(1) (with respect to an intestate share passing to issue, a grandchild will only take if his or her parent, who is a child of the decedent, did not survive the decedent). Absent their own disclaimers, Annabelle and Clara would thus receive the intestate shares of both Lynn and Laura. -8- 38. The intestate rights of Annabelle and Clara in the Decedent's Estate only ripen into enjoyment if all of the Trust beneficiaries disclaim their interests in the Trust and if Lynn and Laura disclaim their own intestate rights. 39. Accordingly, Petitioners also seek authorization, as guardians of the estates of Annabelle and Clara with respect to the minors' intestate rights in the Decedent's Estate, to disclaim the same. As a result of such disclaimers, the Decedent's wife, Marilyn, would he the Decedent's only intestate heir, and all of his intestate estate, including the Pension, would pass to her outright. Marilyn could then roll over the Pension distribution to an IRA and, thus, defer federal income taxation on the Pension proceeds until withdrawals are made therefrom. WHEREFORE, Petitioners Lynn Tosh and Laura Puskarich respectfully request that this Court: (i) appoint them as guardians of the estates of Annabelle Tosh and Clara Tosh solely with respect to the Pension, the Trust and Estate and appoint them as guardians of the estate of Miyabi Gaskell solely with respect to the Pension and Trust; and (ii) approve the Petitioners' disclaimers, as such guardians, of the three minors' interests therein. Dated: ~ ~,, ,2004 Respectfully submitted, BUCHANAN INGERSOLL PC Ig.~2R0'76W°l fgang, ~ 0 Samuel J. Goncz, Esquire I.D. #66820 One South Market Square 213 Market Street, 3rd Floor Harrisburg, PA 17101-2121 (717) 237-4800 -9- EXHIBIT A LAST WILL AND TESTAME~ OF VIRGIL F. PUSKARICH I, VIRGIL F..PUSKAKICH, of Cumberland County, Pennsylvania, declare this to be my Last Will and revoke any Will previously made by me. ,ITEM ONE I direct that my remains be cremated and the arrangements be made with the Cremation Society of pennsylvania. ITEM TWO I direct that all my just debts, expenses of my last illness, and funeral expenses shall be paid from the assets of my estate, as soon as practical after my decease, as a part of the administration of .my estate. ITEM THREE I bequest any and all motor vehicles and their acCessories and equipment, all personal effects and belongings, all jewelry, clothing and other articles ofhousehold use or ornament and all other tangible personalty oflikenature (not including cash and securities), and all insurance policies relating to such property, owned by me at the time of my death to my wife, MARILYN PUSKARICH, if she survives me for a period of thirty (30) days. If she predeceases me, I give my said personal property and the insurance thereon to my then living children to be divided among them as they agree. If they cannot agree, then the said personal property shall be sold and the proceeds distributed to them in equal shares. 1 ITEM FOUR Subject to the payments ha Item Two, my Personal Representative shal1 distribute the net income and principal of all of the remainder of the residue of my estate, including without limitation, all property or interest therein acquired by me or to or which I may become entitled aider the execution of this Will, and all property over which I shall have a power of appointment or disposal which I shall not have otherwise exercised, or refused to exercise, to the named Trustees to hold IN TRUST, as' part. of the Trust Estate of the VIRGIL F. PUSKARICH Family Trust Agreement dated t day of January, 2003, as amended at any time prior to my death, or, if said Agreement is no longer in effect, to hold, IN TRUST, on the terms and conditions specified in said Agreement on the date ofthisWill or of the last Codicil hereto, which like effect as if they were set forth herein verbatim. ITEM FIVE If my wife, MARILYN PUSKARICH, shall die simultaneously with me or there is no sufficient evidence to establish that my wife and I died otherwise than simultaneously, I direct that I shall be presumed to have predeceased my wife, MARILYN PUSKARICH, notwithstanding any provision of the law to the contrary and that the provisions of my Will shall be construed on such presumption. ITEM SIX I authorize my Executor to claim administrative expenses as a deduction Upon my estate return or upon an income tax return or returns as he or it in his or its discretion shall considered to be in the best interests of my. benefi¢im'ies, with no'duty t,:; '.,flaRe adjustments between income and Principal as a result thereof. 2 ITEM SEVEN - · I direct that all estate, inheritance and other taxes ~n the nature thereof, together with any interest and penalties there°n, becoming payable because of my death with respect t° ~he prop~ constituting my ~oss estate for d~th tax purposes, whether or not such propeH3~ passes under this W~II, shall b~ paid from the principal of my residuary estate, and no person receiving or having a beneficial interest in any such property, whether under this Will or otherwise, shall at any time be required to contribute or to refund any pan hereof, PROVIDED, however, that this direction shall not apply to taxes on my prOperty included in my estate solely because of a pOwer ofappoimment thereover which I possess but have not exercised or on any qualified terminable interest or to any generation skipping transfer. ITEM EIGHT All of my insurance policies which provide indemnity for the loss of any of my personal or real property by fire, windstorm or other similar casualty (including any claim for the loss against any insurance company), I give and bequest, respectively, to those persons or corporations, as the case may be, who shall become the owners of such properties by reason of my death, whether such ownership be acquired under the provisions of this' Will, by survivorship or by other means. ITEM NINE Any and all payment or payments.of any sum or sums, whether in cash or in kind and whether for principal or income, payable to the said beneficiaries of my estate shall be free from anticipation, assignment, pledge, or obligation of any beneficiary, and shall not be subject to any eXecution or attachment. ITEM TEN I appoint my Wife, MARILYN PUSKARICH, Executor of this my last Will. Should my Wife, MARILYN L. PUSKARICH, fail to qualify or cease to act as Executor, ! appoint my daughters, LYNN M. TOSH and LAURA M. PUSKARICH, Co- Executors of this my last Will. I appoint SUELLEN M. WOLFE, attorney of my estate. No bond shall be required of any fidudary hereunder or in any jurisdiction. No fidudary hereunder shall have any liability for any mistake or error of judgement made in good faith. ITEM ELEVEN My Personal Representative shall have the following powers in addition to those vested in them by law and by other provisions of my Will, applicable to all property, including Property held for minors, whether principal or income, exercisable without court approval, and effective until actual distribution of all property. Such list of powers is not exclusive and it is not meant orintended for the powers hereinafter set forth to be exclusionary and in derogation of any remaining statutory powers; and To retain, any or all property owned by me at the time of my death in the form in which it then exists; acquire by purchase or otherwise or retain, temporarily or permanentl);, any kind of realty and personalty including stocks and unsecured obligations, undivided interest, interests in investment trusts, mutual funds, legal and discretionary common trust funds, leases, any property belonging to my estate, and property which is outside of my domicile, all without diversification as to kind or amCunt and w~tho~ ~t · being limited to investments authorized by law for trust funds, (including the discretion to retain as an investment any obligation or obligations owing to me by any corporation in which I have a stock interest at the time of my death) and hold funds uninvested, or deposit any moneys in one or more savings or other banks in any form of account whether or not interest bearing; and To vote in person or by general, limited or discretionary proxy, with respect to any investments that may be owned by my estate or any trust, or consent to any purpose, in respect of any stocks or other securities; exercise or sell any rights of subscription or other right in respect thereof; and To hold two or more trusts or other funds in one or more consolidated funds, in which the separate trusts or funds shall have undivided interest; and To sell, exchange, or otherwise dispose of realty and personalty publicly or privately, wholly or partly on credit or for any consideration including stocks, bonds or other corporate obligations and grant options for the purpose, exchange or other disposition of any such property; and To pay general legacies, establish trusts, divide or distribute principal, in kind or in money, or partly in each, or by way of undivided interests, even if shares be composed differently; and To delegate discretionary powers to agents, remunerate them, and pay their expenses, employ and pay the compensation of accountants, custodians, legal and investment counsel; and To ~ assign, alter, extend, compromise, release with or without consideration, or submit to arbitration, obligations or claims, including taxes, held by or asserted against them or which affect estate or trust assets; and To hold property in the name of nominees; and To borrow money from themselves or others and pledge or mortgage any property, for the · ' ' ' ' '~1 ! h° ° ~ ' payment of taxes, debts, legacies or ~xp~nses or any other propose which u.~ tn~r opxmon w~ll facilitate the administration of my estate or any trust; and To manage, retain, improve, alter, subdivide, develop, dedicate to public use or lease real property or grant easements with respect thereto for periods to begin presently or in the future without regard to statutory restrictions on leasing and even though any such period may extend beyond the term of any trusts; and To consent to and participate in any plan for the liquidation, reorganization, COnsolidation or merger of any corporation and security of which is held; and To abandon, in any way, property which the determine not to be Worth Protecting; and In connection with the administration of my estate and of any fund hereunder, I direct that all corporate stock distributions in the stock of the distributing corporation ( except such distribution, whether described as stock dividends, stock splits or otherwise, paid in stock of the distributing corporation, where the number of shares of that class of stock distributed to sharehOlders of that class amounts to six (6%) percent or less than the outstanding number of shares of that class on the record date for such distribution), all rights to subscribe accruing on or in respect of any securities held hereunder, all capital gains distributions on shares of mutual funds, and all liquidating dividends'shall be treated as principal; and all other cash or stock dividends accruing on or in respect of any such securities Shall be treated as income; and To make loans out of the trusts to my Executors provided that such loans are made'on adequate security and for an adequate interest; and To allocate any portion °fmy GeneratiOn Skipping Tax exemption under Section 263 l(a) of the Internal Revenue Code, or any similar exemption? exclusion or other benefit allowable under the la-w in force when I die, to any proPerty as to which I am the transferor, within the meaning of Section 2652(a) of the Internal Revenue Code, including any property transferred during mY life, to elect out 'of any deemed allocation or revoke any prior election out, and to exercise the special election provided in Section 2652(a)(3) of the Imemal Revenue Code as to any part or all of the Marital Trust under my above mentioned trust; and Notwithstanding any of the other provisions of this Will and the grant of any power either by common law, statute or as set forth herein, the Trustees shall not Possess or exercise any power, the possession of which could or would in any manner disqualify the portion of my estate so qualified for the purposes of or with respect to the marital deduction under the federal estate tax laws or under any law of any state which may grant a similar marital deduction and which has proper jurisdiction of my estate upon my death for estate or similar tax purposes; and To join my wife in making a joint income tax or'gift tax return or to execute a consent to any gift made by my wife for any fiscal Year that included the date of my death or for any period thereto, and in connection therewith, to pay such amounts of tax, imerest and penalty as they may deem advisable, even though not attributable entirely to my income or git~s without requiring an indemnification agreement. IN WITNESS WHEREOF, I have signed, sealed, published and declared this to be my Last Will and Testament, consisting of eight pages plus the Acknowledgment and Affidavit, in the presence of the persons witnessing it at my request thi~,/~ay of January, 2003. 7 The preceding instrument, consisting of this and seven other typewritten pages, each identified by the signature of the Testator, was on the date thereof signed, published and declared by VIRGIL F. PUSKARICI-I, the Testator herein, named, as and for his Last Will and Testament in the presence of us, who in his presence, at his request, and in the presence of each other have subscribed our names as wimesses hereto. Name Address Name /2- ~,ro O~-.~ ~,o A~-~,-.~'~, /Tos-'o Address Address 8 ACKNOWLEDGMENT AND AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: · SS~ COUNTY OF DAUPHIN w~. man. F. PUSr,~ac~ ~f'~,/,~ ~/~- 4~';/~ ,AND Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, being first duly sworn, do hereby declare to the undersigned authority that the Testator signed and executed the instrument as his Last Will and Testament and that he signed willingly, and that he executed it as his flee and voluntary act for the purpose therein expressed, and that each of the wimess~, in the pre~-nce and hearing of the Testator, signed the Will as wimess and to the best of his knowledge the Testator was at the time eighteen years of age or older, of sound mind and under no constraint or undue influence. - . ' ! ./ Witness (SEAL) (SEAL) (SEAL) Witness '}.'/ ~' ~ Subscribed, sworn to and acknowledg~d.befol'ep' me by VIKGIL F,.PUS~CH,'the and subscribed and sworn to me by._~<~ //-~ ,,_. ,,~f'/. fi<L./--/ ~es, thi,~y of January, 2003. Notary Public ....... : (s~.~) l~.~.... . Testator, EXHIBIT B VIRGIL F. PUSKARICH FAMII.Y TRUST AGRF. EMENT THIS AGREEMENT, made thi~$~t~day of January, 2003, by and between VIRGIL F. PUSKAR~CH, of Cumberland County, Pennsylvania, hereinafter called the "Grantor", MARII.YN PUSKARICH and SUELLEN M. WOLFE, hereinafter called the "Trustee*. In the event that MARILYN PUSKARICH or SUELLEN M. WOLFE is unavailable or unable to serve as Trustee, the Co-Trustee shall be MELLON BANK. WITNESSETH WHEREAS, the Grantor has caused his life to be insured under certain insurance policies set forth in the "Schedule of Policies°° hereto annexed and made a part hereof, which policies have been or hereafter will be made payable to the Trustee. NOW THEREFORE, in consideration of the mutual covenants and agreements herein contained, it is agreed by and between the parties hereto as follows: ARTICLE I Upon the policies included hereunder maturing by reason of the death of the Grantor (or at such later time as may be specified in any policy), the Trustee, upon being notified thereof, shall collect the amounts payable thereunder and shall hold the same as a trust estate along with any other property that may be received from the Grantor's estate, deposited as a part of the trust estate during the Grantor's lifetime or received from any other source. The net income and principal thereof shall be disbursed in the following.manner: A. 1. If the Grantor's wife, MARILYN PUSKARICH, survives the Grantor or is presumed to have survived him as hereinafter provided, there shall be established a fund to be known as "Trust A", which shall consist of that fractional share of the trust estate determined as follows: The numerator of the fraction shall be equal to the value of the trust estate reduced by the maximum amount, if any, which will produce a federal taxable estate of a value that, a_~er allowing for the available unified credit and the credit for state death taxes other than those imposed solely for the purpose of obtaining the credit allowed under Section 2011 of the Internal Revenue Code, or its equivalent, will result in no federal estate tax being imposed on the Grantors estate. The denominator of the fraction shall be equal to the value ofthe trust estate. Such fractional share of the mast estate shall be determined on the basis finally determined for federal estate tax purposes, shall include only assets that qualify for the marital deduction, assets to the extent possible Upon which there is available no foreign death tax credit, and shall be undiminished by any estate, inheritance or other death taxes. 2. The Trustee shall hold this fund as a separate fund for the benefit of the Grantors said wife and shall pay to her, or expend for her benefit, all the net income therefrom received from and after the date of the Grantor's death in quarter-annual or more frequent installments for as long as she shall live. In addition, the Trustee shall pay such amounts of the principal from Trust A to the G-rantor's said wife as she shall request, up to an including the whole thereof, or in the event the G-rantofs said wife is incapacitated and unable to make such request, the Trustee may expend such amounts of principal from Trust A as it, in its sole discretion, may deem necessary for her health, comfort, welfare, maintenance and support. 3. On the death of the Grantors said wife, Trustee shall distribute the principal of T~-ust A to and it shall become a part of Trust B herein established, to be continued in truest or distributed as provided herein. 2 4. If the Grantor's death and the death of his wife occur under such circumstances that there is not sufficient evidence that they died otherwise than simultaneously, the Grantor directs, for the purposes hereof; that it be presumed that his wife survived him. B. A second trust shall be comprised of the fractional part of the trust estate remaining after the creation of Trust A, which shall be known as Trust B. The net income from Trust B shall be paid to or for the benefit of the Grantor's said wife in quarter annual or more frequent installments for as long as she shall live. In addition, during the same period, the Trustee may pay to the Grantor's said wife, or expend for her benefit, as much of the principal of Trust B as it, in its sole discretion, may deem necessary for her health, maintenance and support. In the exercise of discretion relative to the distribution of principal to or for the benefit of the Grantor's wife, it is the Grantor's desire but in no way his direction that an effort be made to first expend those assets in Trust A and that consideration be given to.the prior utilization of the assets which the Grantor's said wife may have in her own name. C. Upon the death of the Crrantor's said wife the principal of Trust B, or the entire trust estate as constituted at the Grantor's death in the event the Grantor's said wife should predecease him, shall be disposed of as follows: the Trustee shall distribute all the principal and undistributed income then remaining in the trust estate to the Grantor's then-living issue, per stripes, and the trust estate shall terminate, subject to the provisions contained in paragraph D. 1. If any such chid shall die before the complete termination of his or her trust, the Trustee shall distribute the property then held in trust for him or her as follows: a. As to any property over which such ch/Id had the power to withdraw but had not exercised that power, to such persons, in Such shares and upon .such terms and conditions as the said child may by his or her will appoint. b. As to the property over which the child did not have the power to withdraw, or in the event such child failed to exercise the general power of appointment given in subparagraph a above, then all of such property shall be distributed to the issue, per stirt~es, of such child then living, or if such child has no living issue then living, then to the issue of the Grantor then living, per stirpes; provided, that if the share of the Grantor's estate is then being held in trust by the Trustee for any such issue, the share herein apportioned shall be added to and form a part of the principal of the trust held for the benefit of such issue. 5. If none of the Grantor's issue is then living, or if all of the Grantor's issue shall predecease the survivor of the Grantor and his said wife, the Trustee shall divide the principal of the trust estate as then constituted into two (2) equal shares and distribute, outright and free of trusts, said shares as follows: a. One-half (~), hereof, to the Grantor's sister-in-law, PAMELA GODWIN McMAHON; otherwise to her then living issue, per stirpes; b. One-half(~), hereof, to the Grantor's sister, DARLENE BOHNAK. otherwise to her then living issue, per stirpes. D. If any beneficiary entitled to receive a share of principal hereunder shall be under the age of twenty-five (25) years, such share shall not be distributed to him or her but shall be retained by the Trustee hereunder until the beneficiary attains the age of twenty-five (25) years, at which time the principal shall be paid to him or her, free oftrust. During such time, the Trustee shall pay the net income from his or her separate share in quarter-annual or more frequent installments, to or for the benefit of such beneficiary. Ifthe Trustee deems the net income to be insufficient to provide for the health, maintenance, support and complete education, including preparatory, college and postgraduate or professional training of such beneficiary, the Trustee may also expend so much of the principal of his or her share as it deems necessary therefor; provided, however, that such distributions of net income and principal may be applied either directly or by making payment to his or her Guardian or Other legal representative or to the person with whom he or she resides without 'liability on the part of the Trustee to see to the application thereof. If any such beneficiary shall die before reaching the age of twenty- five (25) years, the property held in trust for him or her, together with any accrued or undistributed income, shall be distributed to the beneficiary's issue then living,/~er st/rpes. If the beneficiary has no living issue then living, the Trustee shall distribute the trust property to the person or persons who would be entitled thereto if the beneficiary had then died intestate and unmarried, se'~Zed and possessed thereof and domiciled in the Commonwealth of Pennsylvania. E. Should the principal of any trust hereinbefore created be or become too small in the Trustee's discretion to make the establishment or continuance of the trust advisable, the Trustee may terminate the trust and make immediate distribution of the then remaining trust property to the beneficiary or beneficiaries then entitled to the income of the trust property. The receipts and releases of the distributee will terminate absolutely the fight of all persons who might otherwise have a future interest in the t/ust, whether vested or contingent; without notice to them and without the necessity of filing an account in any court. In addition, the Grantor specifically exonerates the Trustee from all liability or accountability to any such persons having or claiming a future interest in the trust, whether vested or contingent, with respect to the exercise of the discretionary authority hereinabove granted. ARTICLE TWO All shares of principal and income shall, until actual distribution to the respective beneficiaries, be free from the debts, contracts, alienation and anticipation of any beneficiary or beneficiaries, and the same shall not be liable to any levy, attachment, execution or sequestration. ARTICLE THREE Upon the death of any income beneficiary, any accrued, accumulated or undistributed income held or received by the Trustee shall be paid to the person or persons for whose benefit the principal producing such income is continued in trust or to whom such principal is distributed under the terms hereof. ARTICLE FOUR The Trustee shall receive compensation on the gross income of the trust, and in addition thereto, a reasonable fee based on the market value of the principal of the trust estate, which fee shall be in accordance with the then prevailing rate of compensation charged by the Trustee for like services, such compensation not to exceed that which would be allowed by a court having jurisdiction over a similar trust. Prior to the funding of the trust created hereunder, the Trustee shall receive no compensation for its services. ARTICLE FIVE The Grantor's Will and other trust agreements created by the Grantor may provide for additions to this trust; and consequently such other instruments should be examined in with the making of any alteration, amendment, change, revocation or termination of this trust, or part thereof; to determine what changes, if any, should be made in such other instrument; and more important, after the Grantor's death, what consequences, if any, the terms, conditions and provisions of this trust and such other instruments have on the continued existence and operation of each other. ARTICLE SIX The Grantor reserves the right to himself, or to any other person, at any time, and fi-om time to time to add cash, securities or other property to the corpus of the trust estate created herein, by deed, gift, or will; and all such additions shall be held, administered and distributed in accordance with the provisions of this Agreement. ARTICLE SEVEN No amounts of money or property exempt fi-om federal estate tax and received by the Trustee hereunder as a result of my participation qualified pension or profit sharing plan as defined by the Internal Revenue Code, shall be used in any manner to pay taxes attributable to my death, or any of my debts or administrative expenses incurred in administering my estate. ARTICLE EIGHT The Grantor reserves the right and power to amend or revoke this Agreement at any time and fi-om time to time, either in whole or in part, without the consent of the Trustee or any beneficiary hereunder, by written notice to the Trustee to. that effect; provided, however, that the duties, responsibilities and rate of compensation shall' not be altered or' modified without their-written consent. Any Trustee shall have the right to resign at any time as Trustee upon not less then thirty (30) days written notice to the Grantor, if any, and if not, to the current income beneficiary. Upon the effective date of such resignation, all duties of the resigning Trustee shall cease, except for the duty to account and turn over the trust assets. During his lifetime, the Grantor shall have the right, in his sole and absolute discretion, to remove the Trustee at any time, provided, however, that simultaneous with the removal of the Trustee, he shall nominate and appoint a successor Trustee. If any Trustee fails or ceases to serve during the lifetime of the Grantor, the Grantor shall immediately appoint a successor Trustee to fill the vacancy. ARTICLE NINE The Trustee and its successor shall have ail the power and authority granted to the Trustees by the State of Pennsylvania; and in addition to any not in limitation thereof they shall have the following powers and authority unrestricted by statute or rules of law regulating investments by Trustees; To retain any and all property owned by the Grantor at the time of the Grantor's death in a form in which it then exists; acquire by purchase or otherwise, and retain, temporarily or permanently, any kind of realty and personalty, including stocks and unsecured obligations, undivided interests, interest in investment trusts, mutual funds, legal and discretionary common trust funds, leases, and other property of Grantors domicile, all without diversification as to kind or amount and without being limited to investments authorized by law tbr trusts funds (including the discretion to retain as an investment any obligation or obligations owing to the Grantor by any corporation in which the Grantor has a stock interest at the time of the Grantors death (including any common trust fund administered by the Trustee pursuant to the Uniform Common Trust Fund Act) and hold funds uninvested or deposit any monies in one or more savings or other banks (including the Trustee's or any owned or affiliated with it) in any form of account whether or not income bearing; (provided, however, that non-income producing or unproductive property shall not be retained as an asset of the trust for more than a reasonable time during the lifetime of the Crrantofs said wife, or if Grantors said wife shall by written instrument delivered to the Trustee, direct the Trustee to convert any non- income producing property held in the trust estate to income producing property, the Trustee shall within a reasonable time at~er its receipt comply with the direction); To vote irt person or by general, limited or discretionary proxy, with respect to any investments that may be owned by Grantors estate or any trust, or consent for any purpose, in respect of any stocks or other fights in respect thereof} To hold two or more trusts or other funds in one or more consolidated funds, in which the separate trusts or funds shall have undivided interests; To sell, exchange or otherwise dispose of realty and personalty publicly or privately, wholly or partly on credit or for any consideration including stock, bonds, or other corporate obligations and grant options for the purpose, exchange, or other disposition of any such property; To pay general legacies, establish trusts, and divide or distribute principal, in kind or'in money, or partly in each, or by way of undivided interest, even if such share be composed differently; To delegate discretionary powers to agents, remunerate them, and pay their expenses, employ and' pay the compe~..sation of accountants, custodians, legal and investment counselors; To renew, assign, alter, extend, compromise, release, with or without consideration, or to submit to arbitration, obligations or claims, including taxes, held by or asserted against or which affect estate or trust assets; To hold property in the name of a nominee; To borrow money from themselves or others and pledge or mortgage any property, for the payment of taxes, debts, legacies or expenses or for any purpose which in their opinion will facilitate the administration of the Grantor's estate or any trust; To-manage, retain, improve, alter, subdivide, dedicate to public use or lease real property or grant easements with respect thereto for periods to begin presently or in the future without regard to statutory restrictions on leasing and even though any such period may extend beyond the term of any trust; To abandon, in any way, property which they determine not to be worth protecting; and In connection with the handling of the Grantor's estate and of any funds held hereunder, Grantor directs that ail corporate stock distributions in the stock of the distributing corporation (except such distributions, whether described as stock dividends, stock splits or otherwise, paid in the stock of he distributing corporation, where the number of shares of that class of stock distributed to shareholders of that class amounts to six (6%) percent or less of the outstanding number of shares of that class on the record date for such distribution), ail fights to subscribe accruing on or in respect of any securities held hereunder, all capitai gains distributions on shares of mutuai funds, and ail liquidating dividends shail be treated as principai; and all other cash or stock dividends accruing on or in respect of any such securities be treated as income; and To make loans out of the trust estate to the Grantor's Personal Representative, provided that such loans are made on adequate security and for an adequate interest; and l.O Notwithstanding any of the other provision of this Agreement and the grant of any power either by common law, statute or as set forth herein, the Trustee shall not possess or exercise any power, the possession of which could or would in any way disqualify the portion of Grantor's estate so qualified for the purpose of or with respect to the marital deduction under the Federal Estate Tax Laws or under the laws of any state which may grant a similar marital deduction and which proper jurisdiction the estate of the Settlor upon his death for estate or similar tax purpose. ARTICLE TEN The Trustee may pay to the personal representative of the Grantor's estate an mount fi.om the corpus of the trust estate which the said personal representative shall certify as necessary to supplement the Grantor's estate in order to pay funeral expenses, and all bequests, taxes, debts, and expenses of administration or the Trustee may pay the same directly. In consideration of the Trustee delivering any assets held hereunder to the personal representative of the .Grantor's estate, the personal representative shall indemnify the Trustee and shah save the Trustee harmless fi.om · liability for any claim that any creditor (whether general creditor or taxing authority) may have against the assets held by the Trustee under this Agreement. ARTICLE ELEVEN The Grantor reserves to himself during his lifetime all payments, dividends, surrender values, fights, benefits, option or privileges of any kind which may accrue on account of any of the policies included hereunder, and the right at any time to change the beneficiary thereof or to assign, pledge or use said policies or any of them, to borrow money thereon or for any other purpose, without consent, approval or joinder of the Trustee or any beneficiary hereunder. Further, without limiting his rights hereunder, the Grantor reserves the right to withdraw any and all of the policies or other designated benefits subject to this Agreement. It is the intent that this Agreement shall be operative only with respect to the proceeds of such of the policies subject to this Agreement as in terms may be due and payable to the Trustee at the time of the death of the Grantor and thereafter, after deduction of all charges against said policies by way of advances, loans, premiums or otherwise, and the Trustee shall in the absence of express notice of inaccuracy, be protected on accepting as correct the statements and figures of the insurance pOlicies as to the net proceeds of said policies. ARTICLE TWELVE Notwithstanding the powers invested in fiduciaries or by the provisions of this trust, no Trustee acting hereunder, who is also a beneficiary, shall be permitted to participate in any decision or make or withhold distribution hereunder to or for his or her own benefit or to determine whether the receipt or disbursement shall be allocated to principal or income. No Trustee may participate in any decision to make or withhold distribution hereunder to or for the benefit of any person he or she has a legal liability to support. In such cases, the decision of the remaining Trustee or Trustees shall control. Each Trustee shall have the right at any time to relinquish any power granted to such fiduciary under the provisions of this trust or by law. It is intended that the trust created in Article I.B. of this document shall not be includable in the taxable estate of my said wife. Therefore, Grantor directs that any rights, powers, duties, authority or discretion given either to any Trustee or my said Wife, by any such trust or any other, provisions contained herein, or in any amendment hereto, which conflict with this intention or which will result in imposing any death or estate tax upon or 12 measured by the corpus of such trust shall be reconciled, revoked or ignored, or any adequate provision shall be so amplified as to accomplish said objective. ARTICLE THIRTEEN The Trustee shall be under no obligation to pay or to see to the payment'of premiums, assessments or other charges upon the policies of insurance included hereunder and shall be responsible for the proceeds only When, as and if paid to it, and during the lifetime of the Grantor shall be under no obligation with' respect to such policies included hereunder except for the safekeeping of those deposited with the Trustee unless otherwise expressly agreed herein. ARTICLE FOURTEEN The Trustee may render an accounting at any time to the then beneficiaries of the trust estate, or the legal or natural guardian of any beneficiary, and the Grantor; and the written approval of such persons shall be final, binding and conclusive upon all persons then or thereafter interested in this trust for that beneficiary. The Trustee may at any time, but is not required to render a judicial account of its administration of the trust. ARTICLE FIFTEEN It is the intention of the parties hereto that this instrument and all questions as to the construction, validity, effect and administration thereof shall be governed by the laws of the State of Pennsylvania. ARTICLE SIXTEEN It is mutually understood and agreed that this Indenture shall extend to and be obligatory upon the Executors, Administrators, Legal Representatives and Successors, respectively, of the parties thereto. IN WITNESS WHEREOF, ~L~ay of January, 2003. the parties hereto have executed this Trust Agreement on this WITNESS: WITNESS: WITNESS: GRANTOR: ..,,~ j t/// ~ t./_M~/~ TRUSTEE: TRUSTEE: 14 STATE OF PENNSYLVANIA COUNTY OF DAUPHIN 'SS: On this ~ay of January, 2003, before me, a Notary Public, personally appeared VIRGIL F. PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained.  , I have hereunto set my hand and official seal. Notary Public (SEAL) 15 EXHIBIT C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: ) ) ESTATE OF VIRGIL F. PUSKARICH, ) ) Deceased. ) No. 0045 of 2004 VERIFICATION AND CONSENT TO APPOINTMENT AS GUARDIAN I, Lynn M. Tosh, verify that the statements contained in the foregoing Petition for Appointment of Guardians of the Estates of Minors and to Approve Disclaimers by Guardians of Minors' Contingent Interests in Decedent's Estate and Trust, are true and correct to the best of my knowledge, information and belief. I understand that any statements made in such Petition are subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to author/ties. I further certify, in conjunction with the foregoing Petition, that I am willing to serve as a guardian of the estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell that are derived from the Estate of Virgil F. Puskarich and the Virgil F. Puskarich Family Trust if appointed by this Honorable Court. I further certify, in conjunction with the foregoing Petition, that I consent to the Disclaimers of my minor children, Annabelle Tosh and Clara Tosh, of their interests in the Estate of Virgil F. Puskarich and the Virgil F. Puskarich Family Trust. Lyre'.M. Tosh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ESTATE OF VIRGIL F. PUSKARICH, ) ) Deceased. ) No. 0045 of 2004 CONSENT I, Adam Tosh, father of Annabelle Tosh and Clara Tosh, certify, in conjunction with the foregoing Petition, that I consent to the Disclaimers of such minors of their interests in the Estate of Virgil F. Puskarich and the Virgil F. Puskarich Family Trust. I also consent to the appointment of Lynn M. Tosh and Laura M. Puskarich as guardians of the estate of Annabelle Tosh and Clara Tosh with respect to their contingent interests in the estate of Virgil F. Puskarich and the Virgil F. Puskarich Family Trust. Adam Tosh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ESTATE OF VIRGIL F. PUSKARICH, ) ) Deceased. ) No. 0045 of 2004 CONSENT I, Daniel Gaskell, father of Miyabi Gaskell, certify, in conjunction with the foregoing Petition, that I consent to the Disclaimer of such minor of her interest in the Virgil F. Puskarich Family Trust. I also consent to the appointment of Lyrm M. Tosh and Laura M. Puskarich as guardians of the estate of Miyabi Gaskell with respect to her contingent interests in the Virgil F. Puskarich Family Trust. 1N THE COURT OF COIvIMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ESTATE OF VIRGIL F. PUSKAR/CH, ) ) Deceased. ) No. 0045 of 2004 CONSENT I, Masayo Gaskell, mother of Miyabi Gaskell, certify, in conjunction with the foregoing Petition, that I consent to the Disclaimer of such minor of her interest in the Virgil F. Puskarich Family Trust. I also consent to the appointment of Lynn M. Tosh and Laura M. Puskarich as guardians of the estate ofMiyabi Gaskell with respect to her contingent interests in the Virgil F. Puskarich Family Trust. M' a o Oa ken IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ESTATE OF VIRGIL F. PUSKARICH, ) ) Deceased. ) No. 0045 of 2004 VERIFICATION AND CONSENT TO APPOINTMENT AS GUARDIAN I, Laura M. Puskarich, verify that the statements contained in the foregoing Petition for Appoinmaent of Guardians of the Estates of Minors and to Approve Disclaimers by Guardians of Minors' Contingent Interests in Decedent's Estate and Trust, are tree and correct to the best of my knowledge, information and belief. I understand that any statements made in such Petition are subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities. I further certify, in conjunction with the foregoing Petition, that I am willing to serve as a guardian of the estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell that are derived fi.om the Estate of Virgil F. Puskarich and the Virgil F. Puskarich Family Trust if appointed by this Honorable Court. ,~:~~aura 19I. l~sk~ -- EXHIBIT D Adam Tosh ~ Lynn Tosh Laura Puskafich 5/9~ 7/12/73 Annabelle Tosh Clara Tosh 5/21/00 12/9/02 Darlene Bohnak (Virgil's sister) Cynthia Bohnak David Bohnak 8/5/74 11/28/71 Pamela (Goodwin) McMahon Darlene Bohnak (Virgil's sister) Daniel Gaskell ~ Masayo Gaskell Theodore Gaskell 8/26/57 5/2/69 1 2/7/66 [ Miyabi Gaskell Stephen Gaskell Michael Gaskell - Michelle Gaskell 8/13/70 8/13/70 2/22/72 Adam Tosh - Lynn Tosh 5/9/~ Annabelle Tosh Clara Tosh 5/21/00 t 2/9/02 Laura Puskarich 7/12/73 Cynthia Bohnak 8/5/74 David Bohnak 11/28/71 1/30/95 #1427166-vl EXHIBIT E RELEVANT FAMILY MEMBERS AND CONTACT INFORMATION Marilyn Puskarich, her children, son-in-law and grandchildren: Marilyn Puskarich 2496 Cope Drive Mechanicsburg, PA 17055 Lynn M. Tosh 2215 Spring Run Drive Mechanicsburg, PA 17055 Laura M. Puskarich 320 Charles Road Mechanicsburg, PA 17050 Adam C. Tosh (father of Annabelle and Clara Tosh) 2215 Spring Run Drive Mechanicsburg, PA 17055 Annabelle Lynn Tosh, b. 5/21/2000 2215 Spring Run Drive Mechanicsburg, PA 17055 Clara Marie Tosh, b. 12/9/2002 2215 Spring Run Drive Mechanicsburg, PA 17055 Marilyn Puskarich's sister: Pamela (Godwin) McMahon 35 Grist Mill Road Glen Mills, PA 19342 Pamela (Godwin) McMahon's four sons, daughter-in-law and granddaughter: Daniel James Gaskell Masayo Ida Gaskell Miyabi Ida Gaskell, b. 1/30/95 128 Pinegate Drive Greenville, SC 29607 Theodore James Gaskell 3709 San Pablo RD. South Apt. 2206 Jacksonville, FL 32224 Stephen John Gaskell 4833 Cypress Woods Drive Unit 4105 Orlando, FL 32811 Michael Scott Gaskell 94 Princess Drive North Brunswick, NJ 08902 Virgil F. Puskarich's sister: Darlene D. Bohnak, d 1/11/2004 401 Oliver Avenue Bentleyville, PA 15314 Darlene D. Bohnak's two children: David Bohnak 401 Oliver Avenue Bentleyville, PA 15314 Cynthia D. Bohnak 401 Oliver Avenue Bentleyville, PA 15314 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF VIRGIL F. PUSKARICH ) ORPHANS' COURT DMSION ) ) No. 00045 of 2004 Date of Death: January 4, 2004 wrrRDRAWAL TO THE REGISTRAR OF WILLS: Please withdraw the appearance of Suellen M. Wolfe, Esquire, on be~mifof~ Representative, Marilyn Puskarich, m the above referen//~d 7roceedin8. Sueilen M.w~ife,'Esqmre'~ . v ,- ~/- -- Supreme Court ID ~24438 Harrislmrg, PA 17112 Phone: 717-65%7763 Fax: 717- 671=4815 Date May 24, 2004 ; CERTIFICATE OF SERVICE AND NOW, this~-~/-~y of ~/ , 2004, I, Suoll~ M. Wolfe, Esquire, ~ certify that I have this day served a tree and correct copy of the forgoing Witl~lraw-a of Appearance, by first class mail, postage prepaid, addressed to Counsel for the Pe~'aonal Representative: Date May 24, 2004 Samuel J. Goncz, Esq. Buchanan Ingersoll, P.C. 301 Grant Street, 20a Floor, One Oxford Ctr Pittsburgh, PA 15219 : Su aM. VoW , Supr~m~ Court ID ~24438 Harri~ur8, PA 17112 Phone: 717.-657-7763 Fax: 717- 6714815 IN THE OFFICE OF THE REGISTER OF WILLS FOR CUMBERLAND COUNTY, PENNSYLVANIA INRE: ESTATE OF VIRGIL F. PUSKARICH, Deceased. No. 0045 of 2004 Code: PRAECIPE FOR APPEARANCE Filed on behalf of: MARILYN PUSKARICH, Executor Counsel of Record for the Estate Samuel J. Goncz, Esquire Pa. I.D. No. 66820 BUCHANAN INGERSOLL PC One Oxford Centre 301 Grant Street, 20th Floor Pittsburgh, PA 15219-1410 (412) 562-8800 Firm I.D. No. 038 IN THE OFFICE OF THE REGISTER OF WILLS FOR CUMBERLAND COUNTY, PENNSYLVANIA INRE: ESTATE OF VIRGIL F. PUSKARICH, Deceased. No. 0045 of 2004 PRAECIPE FOR APPEARANCE To The Register Of Wills: Please enter my appearance on behalf of Marilyn Puskarich, Executor, in connection with the above-captioned matter. Respectfully submitted, Buchanan Ingersoll Professional Corporation One Oxford Centre 301 Grant Street, 20th Floor Pittsburgh, PA 15219 (412) 562-8800 #1566109-vl IN RE: ESTATE OF VIRGIL F. PUSKARICH, Deceased IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION 04-0045 ORPHANS COURT PRAECIPE TO ATTACH EXHIBIT AND AMEND PETITION TO: Register of Wills/Clerk of the Orphans' Court Please attach the letter ruling dated August 24, 2004 from the U.S. Department of the Treasury, Internal Revenue Service ("IRS"), attached hereto as Exhibit "F," to the Petition for Appointment of Guardians of the Estate of Minors and to Approve Disclaimers by Guardians of Minors' Contingent Interests in Decedent's Estate and Trust, which Petition was filed June 2, 2004 in the above-captioned matter. This is the IRS letter ruling referenced in paragraph 14 of said Petition. It was issued by the IRS and received subsequent to the filing of the Petition. Paragraph 14 of the Petition is hereby amended to read as follows: 14. A private letter ruling has been obtained from the Internal Revenue Service confirming the federal income tax results of the actions proposed herein. A copy of the IRS letter ruling, dated August 24, 2004, is attached to this Petition as Exhibit "F" pursuant to the Praecipe filed September 10, 2004. DATE: September 10, 2004' BUCHANAN INGERSOLL PC ]g~76~7~q°lfgang' F~q~inO S. Howard Kline, Esquire I.D. #23568 One South Market Square 213 Market Street - 3rd Floor Harrisburg, PA 17101 (717) 237-4800 08/26/2004 10:$8 FAX 202 283 9598 Ms. Marilyn Pur~afich 2496 Cope Drive Mcd~nicsburg, PA 17055 Internal ~Revenue Service DEPARTMENT OF THE TREASURY IN'I'£RNAL REVENUE g£RVICE WASHINGTON, D.C.. 2022,4 AU6 2 ¢ 200 LEGEND: Decedent Spouse Daughter 1 Daughter 2 Grandchild 1 Cn-andchild 2 Sister-in-law Sister Nephew 1 Niece 1 Nephew 2 :N~ece 2 N~phew 3 Nephew 4 Neph~v 5 Truste= Year I Date I Ma~lyn Puskarich L~n M~e Pu~ To~ ~a May P~ch ~belle L~ To~ Ct~ Mafi~ Tosh P~ela ~dw~ Mc~ D~l~e D, Bo~ David C~a D~el ~i =~dor~ G~cll St~h~ ~el G~all ~1~ ~ch ~d Suell~ M. Wolfe 1971 ~ 23, 1997 [~002 08/28/2004 10:~? F~ 202 283 9598 Internal Revenue Service 003 Ms. M.adlyn Puskadch 2 Date 2 Date 3 Date 4 Trust l Trust 2 State Couaty State Statute 1 State Statute 2 State Statute 3 State Statute 4 State Statute 5 Dear Ms. Pnskarich: = Jmxuary 2, 2003 = August 21, 1941 = January 4, 2004 = Virgil F. Puskarich Trust Agreement dated 1/23/97 = Virgil F. Puskarieh Family Trust Agreement dated 1/02/03 = Pennsylvania -- Cumberland County, Pennsylvania = 20 Pa. C.S.A. § 2102 = 20 Pa. C.S.A. § 6201 = 20 Pa, C.S.A. § 6202 =20 Pa_ C.S.A. § 6203 = 20 Pa. C.S.A~ § 6205 This is in respome to the April 1, 2004, requ~t for letter rulings under sections 2056, 2518, 402 and 457 of the Internal Revenue Code ("Code"). The following faots and representations support your l~,ling request. Decedent died on Date 4, survived by his spouse (Spouse), two children (Daughter 1 and Daughter 2), two grandchildren (Grandchild 1 and Grandchild 2), a sister (Sister), and a sister- in-law (Sister-in-law). In addition, Sister had two childxvn, Nephew 1 and Niece 1, and Sister- in-law had five ehil&en, Nephews 2-5 amd Niece 2. Sister died ~rven days after Decedent. Decedent's date of birth was Date 3. Thus, Decedent had not attained age 70 ~ as of his date of death, and would not have attained age 70 1/2 as oft. he date of this ruling request. Decedent had been employed by State from Year I until his death. Decedem was a participant in State's SERS (Salaried Eaiployees Retirement System). It is representefl that SERS is a qualified defined benefit plan under section 401 of the Internal Revenue Code, and is a 08/26/2004 10:57 FAX 202 283 9598 Internal Revenue Service ~904 Ms. Madlyn Puskadch 3 governmental plan with{n the meaning of Code § ztl4(d). Decedent also participated in State's Deferred Compensation Plan (DCP). It is represented that DCP is an eligible deferred compensation plan as del'reed in section 457Co) o£the Internal Revenue Code. Under the terms of both SERS and DCP, upon a participant's dei~Ja, the plan proceeds become payable to the participant's designated beneficiary. However, undex the terms of both pl~ns, and consistent with State law, if the participant does not have a valid beneficiary desi~aion in effect at the time of death, the proceeds are paid to the paxticipant's estate. Decedent had designated Trust 1, an inter vivos trust established by Decadent, as the beneficiary o£Decedent's interests in SI~P..S and DCP. However, on Date 2, Decedent established Trust 2, a revoeable trust, Md executed a new Last Will and Testament. At the same tim~, ]Decedent destroyed the Trust 1 agreement and his prior will, thereby revoking both instruments. After revokin§ Trust 1, Decedent failed to dcsi/nate a new beneficiary of Dcccdent's interests in SERS and DCP. Consequently, at the time of Decedent's death them was no valid beneficiary designation in effect with respect to Decedent's interests in SERS and DCP. Accordingly, the proceeds from each plan became payable to Decedent's estate. Article l~our of Decedent's will provides that the residue of Decedent's estate is to pass to Trust 2. Upon Decedent's death, Trust 2 is to be divided into Trust A and Trust B, both of which are intended to provide for Spouse's needs during her lifetime. Article I(A)(1) ofTrast A provides that if Decedent's Spouse survives Decedent or is presumed to have survived ~m; Trust A is to be established. Trust A is to be funded with a shar~ of Decedent's estate that is determined by a fractiom The numerator of the fraction is the amount that, if deductible as a marital deduction, will produce a federal taxable estate of a value that, after allowing for the available unified credit and the crc~t for state death taxes other than those imposed solely for the purpose of obtsl,lng the unified credit allowed under section 2011 will result in no federal estate tax being imPOsed on Decedent's estate. The dcnominalor of the fraction is thc value o£the h'tmt estate. Tho fractional share is to be d~t~ined on the basis of the amounts finally determined for federal estate tax purposes. The fractional sbar~ is to contain only assets that qualify for the marital deduction and assets, to the extent possible, upon which them is available no foreign tax credit. Thc fractional share is to be undiminished by any estate, inheritance or other death taxes. Article l(A)(2) provide~ that Trust A is to be held for the benefit of Spouse. Trustee is to pay Spouse, or expend for her benefit, all of the net income rcccived after the Deccdent's date of death in quarter~anmial installments or more frequent installments for Spouse's life. In addition, 08/26/2004 10:$7 FA~ 202 283 9598 Interna~ ~v~ ........ . ........ Ms. Mafilyn Puskarlch 4 of principal from Trust A to Spouse as she may r~% up to and Trustee is m pay such amounts that Spouse ~s incapacitated and unable to make the Includiag the whole thereof or in the &vexxt request, Trustees may expend such amo~mts from prixacipal of Trust A ~s it may deem, in their clisctction, necessary for SpoUse's health, comfort, welfare, maintenar~ce and support. Under Axti~le 1(A)(3), on the death, of Spouse, Trustcc is to distribute the principal of Trust A to Trust B. , , rustB tobeestablishedUponDeccdent'scleatlListob¢ 'c e 1 provides that T '. . . _:_:_.. ~ ~stablisbament of Trust A. ' A_m 1 . ~) ...... ~.~..trust es~teremamm~,~.~- the comprised of the I/mc-uomqi pax~ u, ,~ or for the benefit of Spouse in quart~ amuusl or more The act income of Trust B is to be paid to frequent installments for Spouse's life. In addition, Trustee may payto Spouse, or expend for her benefit as much of the prlucipal o£ Trust B as Trustee in its sole discretion, 'may deem n~cessary for SpoUse's health, maintenance and support. IJpon Spouse's death the property of Trust B is to pass to D~cedent's then li-~_ug issue, I~ sfi__~.~_~. The share of my daughter who is then deceased will be distxibutable to the cl~oeased daughter's then living issue, pe.[ ~ or if she has no then liviag issue, to the Decedent's other If the Dex~adent has no then h~ing issue, the feminizing trust living issue in thc same maoner- or if she is not thou living to Sister-in- property will be distributable one-hail to Sister-in-law, law's then-hYing issue ~ ~ and on~-halfto Sister, or if she is not then living to Sister's th~n-living issue P_9_[ lai!t~- It is proposed that, Spouse, Child 1, Child 2, Grandchild 1, Grandchild 2, Sister (through her legal representative), Sister-in-law, Nephew 1 aad Niec~ 1, Nephews 2-5 and Niece 2 will' disclaim their respective interests under Trust 2. In addition, it is rcprcsc~tod that in the case of thre~ beneficiaries who are minors, a guardian will be appointed for purposes of ex,outing'their disclaimers. Under State law, as a'rcsult of the disclaimers by all the ben¢ficiarka of Trust 2, thc AccordizLgly, thc estate disclaimants will be treated as if they had all p:ed~ceased Decedent- of debts and residue (which includes the proceeds of SERS and DC-T), after the payment expenses, will become distributable to Decedent's heirs det~i~;i~ed under State law. It is further proposed fl~t Child 1, Child 2, Grandchild 1 and GTa~dchild 2 will disclaim ~ach of their intcstal¢ interests in thc residue of Decedent's estate. These disclairnants will also be treated as predeceasins the Decedent with respect tO the disposition o£ the m. sidue. Under State Statute t, if a d¢ccdcmt di~s intcsta~ survived by a spoUSe, with no surviving issue or parents, thc spoUSe will receive the decedent's entire estate. AccordinglY, Spouse will become the s01e beneficiary of Decedent's residuary estate, including the interests in SERS and DCP ben¢iits. 08/25~2004 10:$8 FAX 202 283 9698 Internal Revenue Sevvice ~008 Ms, Marilyn Puskarich 5 It is represented that at the time of his death, Decedent was a resident of County, and that Decedent's will has been probated before the Register of Wills of County in acco .rc~ce with State law. It is represented that the proposed disclaimers will be in writin$. It is represented that the disclaimers of'the beneficiaries of'Trnst 2 will be ~iled with Decedent's exectttot and the trustees o£ Trust 2, and thai.the disclaimers of the intestate interests will be filed with Dccedent's executor and the County Register of Wills w/thin nine months o£the Dccedent's dale of death to be approved by the appropriate County Cottrt. It is represented that none ofthe flisclaimants will have aCCepted any of the income or other benefits of the disclaimed property prior to making thc disclaimers. ' Upon thc approval oft.he disclaimers and the filing o£the disclaimers with the County Register of Wills, tho residue of Decedcnt's estate, including the distributions from SERS and the DCP, will pass to Spouse by operation of State law. Within 60 days of receipt of the distributions from SERS and tho DCP, Spouse w/Il roll over said distributions into an individual retirement ac, count (IRA) set up and maintained in her name. Said distributions and relievers will. occur no later than December 31, 2004. Based on thc above facts and representations, the following rulings are requested: 1. The proposed disclaimers will be qualified disclaimers for purposes of section 2518; 2. The amount passing to Spouse by intestacy as a result of the disclaimers will bc trcaled as passing directly from Decedent to Spouse, and will qualify for the estate tax marital deduction; 3. As a result of the disclaimers ref~=a-enced herein, Spouse will be treated as having r~ceived Decedent's interest in State's SERS directly from Decedent tot purposes of Code § 402(c); 4. As a result of the disclaimers referenced herein, Spons~ will be treated as having received D~cedent's interest in State's DCP directly from the Decedent for purposes o£Code § 457(e)(16); Pursuant to Code § 402(c), Spouse is eligible to roll over a distribution of Decedent's interest in SERS into an individual retirement account (IRA) set up aid maintafiaed in the name of Spouse; 6. Pursuant to Code § 457(e), Spouse is eligible to roll over a d/sm'but, ion ot'Decedent's interest in DCP into an individual retirement account (IRA). 0~/26/2004, 10:58 FAX 202 283 9598 Internal Revenue Service ~007 Ms. Madlyn Puskadch 6 set up and maintained in thc name of Sponsc; and Spouse will not havc to i~clude in her Federal gross income for the year of distribution and rollover (2004) any portion of the distribution from either SBRS aud/or DCP timely rolled over into. an IRA set up and maintained in the name of · Spouse. With respect to your first and second ruling re~luests, Code section 2001(al imposes a tax on the transfer of the taxable estate of every decedent who is a citizen or resident of the United States. Section 2056(a) provides that. for purposes of the tax imposed by ' 2001, the val.ae of the taxable estate is to be determined by deducting from the value of thc gross estate an amount equal to the value of any interest in pwperty that passes or has passed from the decedent to the surviving spouse. Under § 20.2056(d)-2 of the Estate Tax Regulations, if an interest in property passes from a decedent to a person other than the surviving spouse, the person makes a qualified disclaimer with respect to such interest, and as a result of the disclaimer, the properly passes to thc surviving spouse, then the disclaimed interest is treated aS passing directly to the surviving spouse ~om the decedent, for purposes of section 2056. Under section 2046(a), provisions relating to the effect of a qualified disclaimer for purposes of the estate tax chapter m-~ found in secfio~i 2518. Section 251 §(al provides that, ifa person makes a qualifie~l, disclaimer with respect to any interest in property, the disclaimed interest will be treated for gift, ~state, and generation- skipping transfer tax purposes ss ffth¢ in~erest had never been trehsforred to such person. Section 251800) provides that a "qualified disclaimer" means an irrevocable and unqual/fied refusal by a person tq accept au interest in property, but only iff 1) the dise~;mer is in writing; 2) the disclaimer is received by the trangfcrt~r of thc interest or his legal representative no later that 9 months after the date on which the transfer creating the interest in the person making the disclaimer is made, or the date on which the person making the disclaimer attains age 21; 3) the person making the disclaimer has not received the interest or any of its benefits; and 4) as a result of the disclaimer, the interest passes without any direction on the part of the person making the disclaimer to the decedent's spouse or to a person other than the person 08/26/2004 10:59 FAX 202 28~ 9598 Internal Revenue Service ~008 Ms. Mafilyn Puskarich 7 Section 25.2518-2(c)(1) ~ ~ ~ g~, a ~s~im~ is not a qu~fi~ ~sc~m~ ~e~s ~e ~cl~.~ ~ p~s~ ~out ~y ~cfion on ~e p~ of~e ~scl~t to a m~g ~ by apron who is ~o ~ h~ ~ law. Sec6on 25.2518-2(e)(2) pm~d~ ~t in ~e c~e ora ~lalm~ ~ by a d~edent's s~i~g spouse, ~ ~ect to prepay ~sfe~d by ~e ~t. ~e ~m~ sa~fi~ ~e ~t~ of ~ 2518~4) if~ ~st p~ses ~ a spouse or a~o~er S~e Smtu~ 2 ~d~ th~ a pemon ~ w~m m ~t~e~ ~ p~ wo~d have d~olv~ by w~ m~, ~lgding, a b~efici~ ~ a ~1~ a p~n ~ed to ~c by ~y, ~ a ~nefic{~ of pencils ~ posen, ~fit-~g ~d o~ ~ployee b~t p~, ~y ~sc],im ~ int~st ~ whole or in p~ by a ~m disclaims. ~ ~sclalm~ m~: d~be State statute 3 provides, in pm't, that a disclakner on bdmlf of a decedent, a mi~or or an incapacitated person may be made by his personal representative, or th~ guardian of his.estate. State Statute 4 provides that if the decedent died domiciled in State, and an interest would haw devolved to the disclaim~t by will or by intestacy, the disclaimer shall be filed with the clerk ofth~ orphan's court division of the county where the decedent died domiciled and a copy of thc disclaimer is to be delivered to any p~rsonal representative, trus~e or other fiduciary in possession of the property. State Statute 5 provides generally that a disclaimer relates back to the date of desth of the decedent. Unless a testator or donor has provided for another disposition, the disclaimer, for purposes of det~rni~g the ~ights of other parties, is treated as the equivalent tn the dischimant having died before, the decedent in tho case of a disposition by will or intestacy. RnHn~ 1- In the present case, tho estate residue (which includes Decedent's interest in SERS and DCP) will pass, under Decedent's will to Trust 2. AIl primary sad contingent beneficiaries of Trust 2 (or their legal representatives or guardians), that is, Spouse, Child 1, Child 2, Grandckild 1, Grsadchild 2, Sister ( through her legal representative), SiSter-in-law, Ncph~v 1 and Niece 1, a~d Sister-in-law, Nephews 2-5, and Niece 2 will disclaim their interests in Trust 2. As a result of these disclaimers, the estate residue, rather than passing to Trust 2, passes to Decedent's heirs 08/26/2004 10:59 FAX 202 283 9598 Internal Revenue Service ~009 Ms. Marilyn Puskarich 8 at law determined under State law; that is, Spouse, Child 1, Child 2, Grandchild 1, and Grandchild 2. Child 1, Child 2, C-~2ndchild I, and Grandchild 2 will disclaim thek interests as heirs at law in thc estate residue. Accordingly, under Stat~ law, thc cntke estate r~sidue will pass'to Spouse. Thus. as a result of the disclaimers, the disclaimed interests will pass, without any direction on the part of the disclalmants to Decedent's surviving spouse, satisfying the requirements of §2515(b)(4) and §§25.2518-2(e)(1) and (2). It is represented that the disclaimers will be valid under State law, and will be delivered to thc approprisi~ partiea no later than 9 months af~ Decedent's death. Further, it is represented that the disclaimants have not accepted any benefits from the in.rests subject to the dJscJsimcrs. Based on the above, we conclude that the proposed disclaimers by the Trust' 2 b~J~eficiarie$ of their respective interests in Trust 2 will be qualified disclaimers under §2518. In ~ddition. we con,Iud& that the disc]~mcrs, to be cxecuted by Child 1, Child 2, Grandchild 1, and Grandchild 2 with respect to their interests as heirs at law in the estate residue, will be qualified disclaimcrs uuder §2518. Rulin~ 2 As discussed above, as a result of thc discJ~imcrs, Spouse will be entitled to receive the estate res/due, which includes D~cedent's i~terests in SERS and DCP. Fu.~er, we have concluded that the discl*imcrs will be qualified disclaimers under §2518, ass,,r~ing the xequixements of§2518(b) are otherwise satisfied. Accorrlln.~ly, under §20.2056(d)~2(b), thc estate residu~ is treated as passing from the D~edent to Spouse for purposes of §2056. Th~refore~ an estate tax marital deduction will be allowed undex §2056 for the value of the residue passing to Spouse. With. respect to your ~ fiRh and seventh (to the extent the seventh applies to S~te's SERS) ~d~g requests, section 402(c)(1) of thc Code provides, ganea'ally, that if any portion of an eligible rollover clislxibution fi'om a section 401(a) of the Code q~alified retirement plan is ~an~fex~d into an eligible r~nent plan, the portion of the dislxibution so ha~af~d shall not be includible in gross income in the taxable year in which palch - Scction ~02(c)(2) of the Code provides that the max~um amount of an eligible rollov~r distribution to which paragrap~ (1) applies shall not ~ceed thc portion of such distribution. which is includible in gross income (determined without regard to paragraph (1)) but states that th~ maximum limitation does ~ot apply to a distribution transfexred to au eligible retiz~n~nt plan dcscrth~ in clause (i) or (ii) of section 402(c)(g)(B). S~tion 402(c)(~) of the Code defi~s "eligible rollovex dismbution' as any distribu6on to au ~nploye~ of all or any portion of the balance to the credit of au employee i~ a qualified trust except the following dist~budons: 08/26/2004 11:00 FAX 202 283 9588 Internal Revenue Service ~010 Ms. Madlyn Puskaflch 9 (A) any distribution which is one ora series of substantially equal pe~i.odio payments (not less frequently than human annually) made -- (i) for the life (or life expectancy) of the employee or the joint lives (or joint life expectancies) of the employee and the employee's, designated beneficiary, or (/d) for a specified l~riod of 10 years or more, (B) any distribution to the extent the dism~bution is required under section 401(a)(9), and (C) any distribution which is made upon the hardship of the employee. Section 402(cXS)(B) of the Ctde defines eligible retirement plan as (i) an individual retirement account described in section 408(a), (ii) an individual re~-ement ,-nuit7 described in s~don 408Co) (othe~ than au endowment contract), ('fii) a section 401(a) of the Code retirement plan, (iv) an ~-nuity plan described in section 403(a), (v) au eligible deferred compensation plan descn"oed in section 457Co) which is mai~t,lned by an el.igt~ole employer descau~bed in section 457(e)(1)(A), and (vi) au anntfity contract described in. section 403(b). Section 402(cX3XA) of the Code provides, generally, that, except as provided in subparagraph (B), section 402(c)(1) shall not apply to any transfer of a distribution made after the 60th day following thc day on wl~ch the distributes received the property distributed. Section 1.402(c)-2, Question and Answer 11, of the Income Tax Regulations states that if an eligible rollover distribution is paid to an empJoyec and the employee contributes all or part of the eligible reliever distribution to an eligt~ble reti~ment plan no later ttmu the 60th day following the date the employee received the distribution, the amount contributed is not ctttrently includible in gross income. Section 402(e)(9) of thc Code provides, generally, if a distn"oution attributable to an employee is paid to the spouse of the employee after the employee's death, scction 402(c) of thc Code will apply to such distribution in the same manner as if the spouse were the employee. $~don 1.402(c)-2 of the regulations, Q&A 12, provides, generally, that if' a distribution attributable to an employee is paid to the empl.oyee's surviving spouse, section 402(c) applies to the distribution in the sam~ toa~er as if the spouse were the employee. Thus, a distribution to the surviving spouse of an cmployee is an eligible rollover distribution if it meets the applicable requirements of section 402(c)(2) and (4) and the associated regulations. Section 1.402(c)-2 of the regulations, Q&A 7Co) provides that any amount that is pa~d beforc January 1 of the year in which the employee att~inn (or would have attained) age 70 Yz will not be treated as required under section 401(a)(9) and thus is an eligible rollover distribution if it otherwise qualifies. 08/26/2004 11:00 F~ 202 283 9398 InTernal Revenue Service ~011 Ms, Madlyn Puskerich 10 R,,li~ 3.5 and 7 (in paffi: With respect to your t~ird~ fifth and seventh (in part) rifling requests, as indicated above, after the disclaimers referenced hercin, Decedent's interest in State's SERE will pass to Spouse. Furth~,more, as a result of the discl~rtem, each disclaimant will be treated as having pred.eccased Decodsall. Th. _us, the disclaimed property, including Decedent s interests m SERS, will not be treated as ha'ring passed to the disclaimsnts prior to passing to Spouse. To the contrary, the disclaimed property will be treated as having passed directly from the Decedent to Spouse. Said tremont will apply for purposes of Coc~ section 402. Thus, will respect to your mird, fifth mad seventh (in part) ruling requests, we conclude as follows: 3. As a result of the disclaimers referenced heroin, Spouse will be treated as. having received Decedent's interest in State's SERS directly from Decedent for pm-poses of Code § t02(c); 5. Pursuant to Code § 402(c), Spouse is eligible to roll over a distribution of Decedent's interest in State's SERS into an individual retirement account (IRA) s~t up and maintained in the name of Spouse; and 7. Spouse will not have to include in her Federal gross income for the year of distribution and rollover (2004) any portion of the distribution f~om State's SEK8 timely rolled over into an IRA set up and maintained in the ~me of Spouse. This ruling letter is based on the assumption that State SEKS is qu~l~ed witMn the meaning of Code § 401(a) aud is a qualified gov~nmental plan within the me~ng of Code § 414(d) as rel:rrcsanted. It also e.~nmes that the IRA. to be ~et up and m~dntained in the n~ne o£ Spouse will meet the requirements of Code section 408(a) ~ represented. Additionally, it assumes the correctness of all facts and representations made with respect thereto. Please note that, pUrSuant to an August 17, 2004 request submitted by your authorized representative on your behalf: the Servi.ce's responses to your fourth, s/xth and seventh (to the extent the seve~zth applics to State's DCP) ruling requests, will be issued to you in a separate ruling letter. A copy oftl~s letter has been sent to your authorized representatives in accordance with a power of attorney on file in tiff s office. 05/26/2004 11:00 FAX 202 283 9598 Internal Revenue Service ~ 012 Ms. MaHlyn Puskafich if yov have any questiom concerning this letter ruling, please contact Lawrence W. Hcbctt, Esquire (I.D. 50-03192) at 202-283-9618 (Phone) or 202-283-9598 (FAX). Sincerely yom-s, Frane~s V. Sloan, Manager Employee Plans Techn~c~l Group 3 Deleted copy of letter mH~g Form 437 INRE: DAVID K. SMITH ALLEGED INCAPACITATED PERSON : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHAN'S COURT DIVISION : : NO. 21-2004-791 PRAECIPE TO DISCONTINUE TO THE REGISTER OF WILLS: Please mark the above-captioned action discontinued as the Alleged Incapacitated Person died on Tuesday, August 31, 2004. Please cancel the hearing scheduled in this matter by this Honorable Court for September 24, 2004 at 11:00 AM in Court Room No. 4. Date: SMIGEL, ANDERSON & SACKS, L.L.P. r D. Royer, omey I.D. No. 76~ an M. Zeamer, E~uire Attorney I.D. No. 82023 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT No. 04-0045 DISCLAIMER WHEREAs, VIRGIL F. PUSKARICH fth ...... t e L~ecec~ent ) died on January 4, 2004, domiciled iu Cumberland County, Pcrmsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A' and 'Trust B" (collectively, the "Trusts"), in which the undersigned, the Decedent's wife, MARILYN PUSKARICH, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in Pact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the properly othe~wvise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the Trust Property"), but not her intestate fights in the Trust Property, to the exlent the Trust Property may othemvise be distributable to the Decedent's intestate he/rs; and WHEREAS, the undersigned has not accepted any interest in or benefit fi-om the Trust Property and has neither received nor shai1 receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and re£use to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or other,vise; provided, however, that the undersigned does not disclaim her intestate rights in the Trust Property, to the extent the Trust Property may otherxvise be distributable to the Decedent's intestate heirs. The undersigned acknowledges, represents and certifies thal she is not now insolvent and ~vas not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encambrance of, given a written Waiver of thc right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property descr/bed above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. SS 6201 ej ~ and a qualified disclaimer as defined in Section 2518 of the Interual Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her hfiirs;-p~'rsonal representatives and assigns. Witn~ess Witness MARILYN PUSKARICH Dale 2 ) SS: On this, the ~day of~, 2004, before me a notary public, the undersigned officer, personally appeared MARILYN PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENrNSYLVANLA ORPHANS' COURT DIVISION VIRGIL F. PUSKARJCH FAMILY TRUST AGREEMENT No. 04-0045 DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (tile "Decedeut") died on Jan3ary 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskar/ch Family Trust Agreement, dated January 2, 2003 (the "Trust A~eement"); and WHEREAs, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in xvhich the undersigned, Laura M. Puskarich, is granted certain interests if she survives the Decedent; rind WHEREAS, the undersigned did, in fact, su~wive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (Sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth ~br disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the stone arises under the laws of the Commonwealth of Pennsylvania or othe~xvise. Thc undersigned acknowledges, represents and certifies that she is not insolvent and was not insolvent at the date ofdcath of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a wr/tten waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or othe~wvise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 ~ ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. ~W. itness ~~__(~_ Laura M. p~t sk afl ch '\ w~mess Date 2 It is the specific Jnte~tion of the nndersi~oned that this Disclaimer constitute a disclaimer under 20 Pa C.S.A. ~ 6201 et ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of an3 subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimcr shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding Upon the undersigncd: i~r heirs, personal representatives and assigns. Witness Laura M. Pnskarich Date COMMONWEALTH OF PENNSYLVANIA COUNTY' OF SS: On this, the ~_day of ~ __ ,2004, before me a notary public, the undersigned officer, personally appeared LAURA M. PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto sc~ my hand and official seal. Notary Public 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY', PENqN'SYLVANIA ORPHANS' COURT DIVIs fON IN RE: ESTATE OF VIRGIL F. PUSKARJCH, Deceased No. 04-0045 DISCLAIMER WHEREAS, VIRGIL F. PUSKAR/CH (the" ,, · Decedent ) d~ed on Jant~ary 4, 2004, domiciled in Cumberland County, Pennsylvania, leaving his last Will, dated January 3, 2003 (the "Will"); and WHEREAS, the Will was duly probated in tbe Office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAs, after providing for the disposition of the Decedent's remains, the pa~nent of his debts, expenses, and taxes, and a bequest of his tangible personal property, the Will bequeaths the residue of the Decedent's Estate to the trustees oftbe Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"), for further distr/bution and administration thereunder; and WHEREAS, al/beneficiaries of the Trust Agreement have disclaimed, or have announced that they will disclaim, their intercsts thereunder; and WHEREAS, the Trust Agreement makes no provision for such a contingency m~d, as a result, Pennsylvania law would rcquirc the trustees to reconvey to the Decedent's Estate all property held, or receivable, under the Trust Agreement; and WIIEREAS, the Will makes no provision for thc disposition ora portion o£the Estate's residue that is disclaimcd; and WHEREAS, accordingly, under Pennsylvania law, the disclaimed property is distributable to the Decedent's intestate heirs; and WHEREAS, the Decedent's putative intestate heirs are his wife, MARILYN PUSKARICH, and their two adult daughters, LYNN M. TOSH and LAURA M. PUSKARICH; and WHEREAS, the undersigned, being one of such daughters, is desirous of disclaiming all right, title and interest in and to the property distributable to the Decedent's intestate heirs as a result of the DecedenPs death (sometimes referred to herein as the "Intestate Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Intestate Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming m~d renouncing her interest in the Intestate Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Intestate Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or ajay of its benefits. 2 The undersigned acknowledges, represents and cerlifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or Iransfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the success/on to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constit,.ne a disclaimer under 20 Pa. C.S.A. § 6201 ct ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said inte,~tion. This instrument shall be immediately effective and shall be binding upon the undersigned, her he/rs, personal representatives and assigns. Witness Date ---? COMMONWEALTH OF PENNSYLVANIA ) .. , , , ) SS: COUNTY OF ,,- , On this, the / ."' .day of · .2004, before me a notary public, the undersigned officer, personally appeared LAURA M. PI JSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF. I hereunto set my hand and official seal. Notary Public 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. 04-0045 ) DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, ~004, domiciled in Cumberland County, Pennsyivania; and WHEREAS, thc Decedent's Last Will and Testament dated January 3, 2003 ("Will") was duly probated in the office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, the Dccedent's granddaughters, Annabelle Tosh and Clara Tosh, who are minors, have certain interests in the Decedent's estatc ("Estate"); and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskmich Family Trust Agreement dated January 2, 2003 ("Trust Agreement") and WHEREAS, the Trust Agreement provides for thc creation and funding of two trusts, known as "Trust A" and "lrust B" (collectively, the "Trusts"), in which minor beneficiaries Annabelle Tosh, Clara Tosh and Miyabi Gaskell are granted certain contingent interests; and WHEREAS, the undersigned, by Order of the Orphans' Court, Orphans' Court Division, Court of Common Pleas, Cumberland County, Pennsylvania, in the matter captioned In Re: Estate of Virgil F. Puskarich, dcceascd, No. 04-0045, has been appointed a Guardian of thc Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell with respect to the interests of said minors in the property of the Estate and the Trusts, as the case may be (sometimes referred to herein collectively as the "Property"); and WHEREAS, the undersigned, in her capacity as a Guardian of, and with respect to, the interests of Annabelle Tush, Clara Tush and Miyabi Gaskell in the Property, has been authorized by said Order of the Orphans' Court to disclaim the Property on behalf of Annabelle Tush, Clara Tush and Miyab/Gaskell; and WHEREAS, the undersigned, on behalf of Annabelle Tush, Clara Tush and Miyabi Gaskell, is desirous of disclaiming all of their right, title and interest in and to the Property; and WHEREAS, neither the undersigned, nor anyone else acting on behalf of Annabelle Tush, Clara Tush or Miyabi Gaskell, has accepted any interest in or benefit from the Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing said Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigmed, on behalf of Annabelle Tush, Clara Tush and Miyabi Gaskell, does hereby h'revocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Property, whether the same ar/scs under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither Am~abelle Tush, Clara Tush, nor Miyabi Gaskell is now insolvent or was insolvent at the date of death of the Decedent, that no such person has made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and no such person has made any sale or other disposition of any interest in the Property pursuant to j udicial process or otheru~-ise. The undersigned, in her capacity as a Guardian of the Estates of Annabelle Tush, Clara Tush and Miyabi Gaskcll, fi~rther -2- acknowledges, represents and certifies that no such person has accepted the Property or m~ interest in the Property as described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~; 6201 et se~q. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. COMMONWEALTH OF PENNSYLVANIA Maw J. _Gouffer. Notary Public ] Silver Spdr~g ~ Curnt~a n~d~unly] -3- IN THE COURT OF COMMON PLE_&S OF CUMBERLAND COUNTY, PEN%'SYLVANiA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT No. 04-0045 :' DISCLAINIER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on Janumy 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust A~eement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trnsts, known as "Trust A" and "%x~st B" (collectively, the "Trusts"), in which the undersigned, L>qm M. Tosh, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, thc undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes rcfc~Ted to laercin as tine "Trust Property"); and WHEREAS, the undersigned bas not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies ~ orth for disclaiming and renouncing her interest in the Trust Property. Nrow, THEREFORE, intending to be legally bound hereby, the undersigned does hereby i~Tevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, t/tlc and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otbet7~ ise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assigqhment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the fight to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 e_[t ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, p~.ers_..onal representatives and assigns. W~tn~s,s Witneis 3mn M. Tosh Date 2 COMMONWEALTH OF PENNSYLVANIA S~TB-OF FEORtDA COUNTY OF SS: On this, the / _day of ~;Sd,/-~,' _, 2004, before me a notary public, the undersigned officer, personally appeared LYNN M. YOSH, known to me (or satisfactorily proven) to be the person whose name is subschbcd to the within instrument and acknowledged that she executed the same for the purposes therein contained. 1N WITNESS WHEREOF, I hereunto set rny hand and official seal. Notary Public Notamal Seal jlly M. Zlmmenman, Notary Public Up'p~r Allen Twp., Gumbed~nd ~ ~y c.~nmission Expires Mar. m, 20O6 Member Pe~sv~a~ A~f-~csat~on O~ No~r, es #1529684 xrl;PGHI General: 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE~SYLVANIA ORPHANS' COURT DIVISION IN RE: ESTATE OF VIRGIL F. PUSKARICH, ) Deceased ) No. 04-0045 ) DISCI,AIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania, leaving his last Will, dated January 3, 2003 (the "Will"); and WHEREAS, the Will was duly probated in the Office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, after providing for the disposition of the Decedent's remai~s, the payment of his debts, expenses, and taxes, and a bequest of his tangible personal property, the Will bequeaths the residue of the Decedent's Estate to the trustees of the Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"), for further distribution and administration thereunder; and WHEREAS, all beneficiaries of the Trust A~eement have disclaimed, or have announced that they will disclaim, their ix~terests thereunder; and WHEREAS, the Trust Agreement makes no provision for such a contingency and, as a result, Pennsylvania law would require the trustees to reconvey to the Decedent's Estate all property held, or receivable, under the Trust A~eement; and WHEREAS, the Will makes no provision for the disposition of a portion of thc Estate's residue that is disclaimed; and WHEREAS, accordingly, under Pennsylvania law, thc disclaimed property is distributable to thc Decedent's intestate heirs; and WHEREAS, the Decedent's putativc intestate heirs are his ~vife, MARILYN PUSKARICH, and their two adult daughters, LYNN M. TOSH and LAURA M. PUSKARICH; and WHEREAS, the undersigned, being one of such daughters, is desirous of disclaiming all right, title and interest in and to the property distributable to the Deeedent's intestate heirs as a result of the Decedent's death (sometimes referred to herein as the "Intestate Property"); and WHEREAS, the undersigned has not accepted any interest in or bencfit from the Intestate Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Intestate Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Intestate Property, whether the same arises under the laws of the Commonwealth of Pcnnsylvania or otheI-,vise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowlcdges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. 2 It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, m~d that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs personal-representatives and assigns. Witness Lynn M. Tosh Date 3 COMMONWEALTH OF PENNSYLVANIA ) ? ) COUNTY OF (f '~,~/*'.~,~/.., '/ ) SS: On this, the .": :~- day of /~/j~:-, / ,2004, before me a notary public, the undersigned officer, personally appeared LYN.~N M. TOSH, known to me (or satisfactorily proven) to be the person whose name is snbscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. / ' Notary Public Jay M Zlmmerman, N~ put~ic ~Jpp~r Nlen Twp., C~.lmbedand ~ Ik'i~ Cxlmmission E~i~ ~r 16, ~ 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH ) FAMILY TRUST AGREEMENT ) No. ) DISCLAIMER 04-0045 WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, the Decedent's Last Will and Testament dated January 3, 2003 ("Will") was duly probated in the office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, the Decedent's granddaughters, Annabelle Tosh and Clara Tosh, who are minors, have certain interests in the Decedent's cstatc ("Estate"); and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement dated January 2, 2003 C'Trust Agreement") and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, thc "Trusts"), in which minor beneficiaries Annabelle Tosh, Clara Tosh and Miyabi Gaskell are granted certain contingent interests; and WHEREAS, the undersigned, by Order of the Orphans' Court, Orphans' Court Division, Court of Common Pleas, Cumberland County, Pennsylvania, in the matter captioned In Re: Estate of Virgil F. Puskarich, deceased, No. 04-0045, has been appointed a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell with respect to the interests of said minors in the propcrty of the Estate and the Trusts, as the case may be (sometimes rcfcrrcd to hcrcin collectively as the "Property"); and WHEREAS, the undersigned, in her capacity as a Guardian of, and with respect to, the interests of Annabelle Tosh, Clara Tosh and Miyabi Gaskell in the Property, has been authorized by said Order of the Orphans' Court to disclaim the Property on behalf ofAm~abelle Tosh, Clara Tosh and Miyabi Gaskell; and WHEREAS, the undersigned, on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, is desirous of disclaiming all of their right, title and interest in and to thc Property; and WHEREAS, neither the undersigned, nor anyone else acting on behalf of Annabelle Tosh, Clara Tosh or Miyabi Gaskell, has accepted any interest in or benefit from the Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing said Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned, on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither Annabelle Tosh, Clara Tosh, nor Miyabi Gaskell is now insolvent or was insolvent at the date of death of the Decedent, that no such person has made any voluntary assigrm~ent or transfer of, contract to assign or transfer, or encumbrance of, given a written ~vaiver of the right to disclaim the succession to and interest in, and no such person has made any sale or other disposition of any interest in the Property pursuant to judicial process or otherwise. The undersigned, in her capacity as a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, further -2- acknowledges, represents and certifies that no such person has accepted the Property or an interest in the Property as described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or thc corresponding provisions of any subsequent fcdcral tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effcctive and shall be binding upon the undersigned, her heirs, personal representatives and assigns. Wltnc .- /-'~6MMONWEALXH OF F'Ef'4NSYLVANIA Notanal Seal Kirk M. Wise, Notary Public Upper Allen Twp., Cumberland County My Commlseion Expires Feb 7. 2008 Date / ' -3- #1608523 ~1 IN THE COURT OF COMMON PLEAS OF CUMBERLANT) COUNTY PENrNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH ) FAMILY TRUST AGREEMENT ) No. 04-0045 ) DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersi=mmd, Cynthia D. Bohank, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigmed is desirous of disclaiming all fight, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refltse to accept any and ali right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that shc has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the fight to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersign~ed further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention oi'the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 ~ ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. Witness Cyntl~,/a D. Bohank Witness Date - 2 STATE OF ~3~ ) SS: On this, the 5 !- day of~,__ ~ ,2004, before me a notary public, the undersigned officer, personally appeared CYNT! IIA D. BOHNAK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, ! hereanto set my hand and official seal. ~ Bentleyville ~',,-:, ' i My Commis~ i ~,'2~, # 1529908-x I ;PGH ]_General, 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN P~E: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) No. 04-0045 ) DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which Darlene Bohnak is granted certain interests if she survives the Decedent; and WHEREAS, Darlene Bolmak did, in l~act, smwive the Decedent; and WHEREAS, Darlene Bohnak died on January 11, 2004; and WHEREAS, the undersigned, the executrix of the estate of Darlene Bohnak, is desirous of disclaiming, on behalf of the Estate of Darlene Bohnak ("Estate"), all right, title and interest in and to the property othemSse distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, neither the undersigned nor the Estate has accepted any interest in or benefit from the Trust Property and neither has received nor shall receive any consideration in money or monies worth for disclainfing and renouncing their interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned, on behalf of thc Estate, does hereby in-evocably, and without qualification, disclaim, renounce and refuse to accept any and all fight, title and interest in and to the Trust Property, whether the same arises under thc laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither she nor the Estate is now insolvent and neither was insolvent at the date of death of the Decedent, that neither she nor the Estate has made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the fight to disclaim the succession to and interest in, and neither she nor the Estate has made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or other~vise. The undersigned further acknowledges, represents and certifies that neither she nor the Estate has accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the Estate, its successors and assigns. Witness Witness C yn~l~i~D. Bohna~< Executrix, Estate of Darlene Bohnak Date STATE OF-FLO,.~..A~4/~,'v% ¢',h i/ ) SS: On this, the 5 ~}x day of i\Jr 'J' *f ,2004, before me a notary public, the undersigmed officer, personally appeared CYNTHIA D. BOHNAK, the executrix of the estate of Darlene Bohnak, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. iN WITNESS WHEREOF, I hereunto set my hand and official seal. #1529928 vl;PGH/ Gene~ah 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT DISCLAIMER No. 04-0045 WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Ageement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, David Bohank, is granted certain interests if he survives the Decedent; and WHEREAS, the undersi=oned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property othera'ise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intcnding to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all fight, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Permsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and ~vas not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance oE given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shalI be binding upon the undersigned, his heirs, personal representatives and assigns. Witness Witness ' 1~ I'.~?' David Bohank Date / 2 STATE OF.gL-4)R-1DA~ ' COUNTY oF ) SS: ) On this, thc ' i~ day of i'! , ,/ ,2004, before me a notary public, the ! undersigned officer, personally appeared DAVID BOHNAK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. otary Public~ - Bentleyv e B-to W ,5t ~ ,' 3 #152991 g-vI:PGH1 Genera]; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreemcnt provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Pamela Godwin McMahon, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all fight, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intcnding to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. ) ) No. 04-0045 The undersigned acknowledges, represents and certifies that she is not now insolvent and ~vas not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the lnternal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. Witness Pamela Godwin McMahon Date STATE OF FLORIDA COUNTY OF ) SS: ) On this, the /:~ day of /5~-,9~'~/_. ,2004, before me a notary public, the undersigned officer, personally appeared PAMELA GODWIN McMAHON,.kno.ar.m.m-m~ (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary PttMic 3 #I 522254-vl ;PGHI Gcnera[; iN THE COURT OF COMMON PLEAS OF CUMBERLANT) COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT No. 04-0045 DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Daniel J. Gaskell, is granted certain interests if he survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigmed is desirous of disclaiming ali right, title m~d interest in and to the property otherwise distributable to thc Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce m~d refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pem~sylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a writtcn waiver of thc right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. Thc undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or thc corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. · Witness "' Daniel J. Gaskell Witness ~ Date 2 COUNTY OF C/,~ .~/O I_? I' ) Onthis, the }e:~ dayof ,2~?~' / ,2004, before me a notary public, the undersigned officer, personally appeared DANIEL J. GASKELL, known to me (or satisthctorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same lbr the purposes therein contained. 1N WITNESS WHEREOF, I hereu~to set my hand and official seal. Notary Publi~' ' -- #1529246-vl 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT No. 04-0045 DISCLAIMER - · WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Yheodore James Gaskell, is granted certain interests if he survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be Iegally bound hereby, the undersigned does hereby in-evocably, and without quali fication, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that hc has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. Witness Witnessi!, Theodore Jan~s Gaskell Date 2 STATE OF FLORIDA ) ) COUNTY OF 0 c~ ~/FtL. ) SS: Onthis, the ~':~,~/dayof //~.-e/z'- ,2004, before me a notary public, the undersigned officer, personally appeared TH EODORE JAMES GASKELL known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHE~ EOF, ! hereup, to set my hand and afficial scai. PERSONALLY KNOWN OR PROVIDED I.D, TYPE OF I.D, -'~"~ ./~/~- Notary ~ublic I[~'?~'~: '4YCCMMISSION#DD13~96 II #1529203-vl - 3 IN' THE COURT OF COMMON PLEAS OF CUMBERLAND COUqNTY, PENNSYLVANIA ORPHANS' COURT DIVISION 1N RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ~ ) No. 04-0045 DISCLAIMER WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Stephen J. Gaskell, is granted certain interests if he survives the Decedent; m~d WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiining all right, title and interest in and to the property othepMse distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersi=maed has not acccpted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing bis interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby i~Tcvocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Prope~ty, whether the same m'ises uudcr the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifics that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. it is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amcndcd, or the corresponding provisions of any subscquent federal tax law, to be filed, recordcd and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. Steph.~: J. 9askell Date STATE OF FLORIDA COUNTY OF '~ SS: On this, the ~-' day of ~/!~; , ~ ,2004, before me a notary public, the undersigned officer, personally appeared STEPHEN J. GASKELL, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF. I hereunto set my hand and official seal. Notary Public ~,:~;'~;,. auiiana Lima :..,'~'. ,= Comm,ss~on # DD301791 ~,-'*._~.~.,-? Expires March 21, 2008 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ORPHANS' COURT DIVISION IN RE: ViRGIL F. PUSKARICH FAMILY TRUST AGREEMENT No. 04-0045 PENNSYLVANIA DISCLAIMER ' WHEREAS, VIRGIL F. PUSKARiCH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding oftxvo trusts, known as "Trust A' and "Trust B" (collectively, the "Trusts"), in which the undersigned, Michael Scott Gaskell, is granted certain interests if he survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes rcferred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to bc Icgally bound hereby, the undersigned does l~ereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property. whether the same arises under the laws of the Commonwealth of Pennsylvania or othem'ise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the propcrty being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifics that he has not accepted property or an interest in the property described above, or any of its benefits. it is the specific intention of the undersigned that this Disclaimer constitnte a disclaimer under 20 Pa. C.S.A. § 6201 et seq. and a qualified disclaimer as dcfined in Section 2518 of the Intcmal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his hcirs, personal representatives and assigns. wi{ness Michael Scott Gaskell Date/ / 2 STATE OF NEW JERSEY ) SS: On this, the /*? '5~day of ~.~' ~ , 2004, before me a notary public, the undersigned officer, personally appeared MICHAEL SCOTT GASKELL, known to me (or satisfactorily proven) to be the person whosc name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary ~ublic 3 September 28, 2004 Butchanan Ingersoll PC One Oxford Centre 301 Grant Street, 20th Floor Pittsburgh, PA 15219-1410 Dear Sir/Madam: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES PO BOX 280601 HARRISBURG, PA 17128-0601 Telephone (717) 787-3930 FAX (717) 772-0412 Re: Estate of Virgi! F. Pu~karich ::' File Numbe~:2104-0~5 This is in response to your request for an extension of time to file the Inheritance Tax Return for the above estate. In accordance with Section 2136 (d) of the Inheritance and Estate Tax Act of 1995, the time for filing the return is extended for an additional period of six months. This extension will avoid the imposition of a penalty for failure to make a timely return. However, it does not prevent interest from accruing on any tax remaining unpaid after the delinquent date. The return must be filed with the Register of Wills on or before 03/27/05. Because Section 2136 (d) of the 1995 Act allows for only one extra period of six (6) months, no additional extension(s) will be granted that would exceed the maximum time permitted. / ,/: Slncer~ely, . ~_~-~.(_..-~:_..~_x_- / ~ ~_.:..,.>,.::_....._/_...~.. Claudia Maffei, Supervisor Document Processing Unit Inheritance Tax Division INVENTORY of all real and personal estate of Virail F. Puskarich deceased. late of 2496 Cope Drive \number ~md street) rQ( -oLj, L{S-' Mechanicsburq (city) , Cumberland County, Pennsylvania, who died (BOrough or Township) JanUary 4. 2004 (date of deal h) PERSONAL ESTATE SCHEDULE American Skandia, One Corporate Drive, Shelton, CT 06484; Annuity Policy #ASXT 349126. Commonwealth of Pennsylvania - payment for unused vacation days. Pennsylvania State Employees Retirement System, 30 North Third Street, Harrisburg, PA 17108. Pennsylvania State Employees Retirement System, 30 North Third Street, Harrisburg, PA 17108 Deferred Compensation. Aviva Life Insurance Company, 108 Myrtle Street, North Quincy, MA 02171, Policy #00021999. Aviva Life Insurance Company, 108 Myrtle Street, North Quincy, MA 02171, Policy #0044663. Conseco Services, L.L.C., P.O. Box 1917, Carmel, IN 46082, Policy #010340049. Croatian Fraternal Union Of America, 100 Delaney Drive, Pittsburgh, PA 15235, Policy #310869. Croatian Fraternal Union Of America, 100 Delaney Drive, Pittsburgh, PA 15235, Policy #293588. Croatian Fraternal Union Of America, 100 Delaney Drive, Pittsburgh, PA 15235, Policy #293709. Teachers Insurance and Annuity Association, 8500 Andrew Carnegie Blvd., Charlotte, NC 28262 Policy #G07721 0-8. '~~' Total Personal Estate Total Real Estate Total Estate 17055 (Zip Code) 29,853.87 42,583.92 1,567,544.49 118,785.62 2,178.44 1,235.47 42,459.00 .5,432.47 ,1,153.38 ==-.1.153.99 (.J """" ) ... , 2,809.32' $1,815,189.97 None $1,815,189.97 REAL ESTATE SCHEDULE REAL ESTATE IN PENNSYLVANIA (Description must be adequate to identify the property. Mortgages, judgments and other encumbrances on real estate should be noted.) None MEMORANDUM OF REAL ESTATE OUTSIDE THE COMMONWEALTH OF PENNSYLVANIA (Do not include value in total of the Inventory) None AFFIDAVIT OF EXECUTOR OR ADMINISTRATOR Commonwealth of Pennsylvania County of j)~ I } ss: Personally before me, the undersigned authority, a Notary Public in and for said County and State, appeared Marilyn Puskarich who, being duly sworn according to law, deposes and says that she is the executor of the estate of Virgil F. Puskarich executor of the estate of Virgil F. Puskarich, deceased, that the foregoing schedules constitute a complete inventory and appraisement of the real and personal estate of Virgil F. Puskarich, deceased, except real estate outside the Commonwealth of Pennsylvania, that the figures opposite each item of real and personal estate in the foregoing schedules are determined and stated by the undersigned to be the fair value of said items as of the date of the decedent's death. Sworn and subscribed before me this .q /P day of '~, 2005. ~ W ~JJ LliL } ~yJ~Lu...2 Marilyn Puskarich COMMONWEALTH OF PENNSYLVANIA Notarial Seal Unda W. Howard, Notary Public l.owerSwatara Twp.. Dauphin County My Commissioo Expires Apr. 20, 2008AI DITIONAL INSTRUCTIONS 1. The inv~m'W~~y,'It'~'jjr~'lfW~lillli"!h\lh'ill'lrilll'te the account is filed or the due date. including any extension. for the filing of the Inheritance Tax Return (9 months from the date of death) whichever comes first. 2. A supplemental inventory must be filed within thirty days of discovery of additional assets. 3. An original and two copies must be filed. 4. Additional sheets may be attached as to personalty or realty. 5. See Section 3301 et seq. of the Probate Estates and Fiduciaries Code of 1972, as amended. 6. The inventory must be typed. 6:~ ." ." '" ~ ".- \?, 0- c:. ~~ ~ Z <J>"'- ",(lJ(fl c:. 9 0<='" -- .....g.3 "" tT\ 0 u::a 0 Gl"'C -- ~ ;~~ i - 0 ~~~ -n .I>- ~ IJ' <,asQ Cl -0 0 _",0 (\) ",,,,=> ~ t: tT\ - ~(j\~ Ul ~ - 0- (\) ~ 0 3\""'" 0- 0 \i11.'1\ "" -n -0 .I>- -" cr 9.. E.. ?- ~ src,a ~YL _ 0 -o=> .".\l!. .....g ~- .....15 "'- ~~ ~ ci 0'" Glenda Farner Strasbaugh Register of Wills and Clerk of Orphans' Court Marjorie A. Wevodau First Deputy Kirk S. Sohonage. Esq Solicitor Register of Wills and Clerk of the Orphans' Court County of Cumberland One Courthouse Square Carlisle, PA 17013 (717) 240-6345 FAX (717)240-7797 INVOICE Bill To: InvoiceNo: Invoice Date: Estate of: Estate No: 287 4/4/2005 VIRGIL F. PUSKARICR 21-2004-0045 Buchanan Ingersoll 301 Grant Street 20th Floor vz Pittsburgh, PA 152191410 Qty 1 1 Fee Description Additional Probate Filing fee for Inherintan Fee 785.00 15.00 Total $785.00 $15.00 Total: $800.00 Checks should be made payable to the Register of Wills. Tenns: Net 30. Please return one copy of this invoice with your payment. Thank you. REV-1500 EX (6-00) W I- ~:$CIl OO::~ Wl1.0 ::J:OO 00::....1 11.a1 11. ~ No 1\1)1) L:~iZO BA TL tLE tuI: '. OFFICIAL USE ONLY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE DEPT. 280601 HARRISBURG, PA 17128-0601 REV-1500 INHERITANCE TAX RETURN RESIDENT DECEDENT FILE NUMBER 21 04 0045 COUNTY CODE YEAR NUMBER t- Z W o w o w o DECEDENTS NAME (LAST. FIRST, AND MIDDLE INITIAL) Puskarich Virgil DATE OF DEATH (MM-DD- YEAR) DATE OF BIRTH (MM-DD- YEAR) 1/4/2004 8/21/1941 (IF APPLICABLE) SURVIVING SPOUSE'S NAME (LAST. FIRST. AND MIDDLE INITIAL) Marilyn Puskarich rn 1. Original Return D 4. Limited Estate rn 6. Decedent Died Testate (Attach copy of Will) D 9. Litigation Proceeds Received SOCIAL SECURITY NUMBER 189-32-3950 THIS RETURN MUST BE FILED IN DUPLICATE WITH THE F REGISTER OF WILLS SOCIAL SECURITY NUMBER D 2. Supplemental Return D 3. Remainder Return (date of dealh prior to 12-13-82) D 4a. Future Interest Compromise (date of death after 12-12-82) [j] 5. Federal Estate Tax Return Required 00 7. Decedent Maintained a Living Trust (Attach copy of Trust) L 8. Total Number of Safe Deposit Boxes D 10. Spousal Poverty Credit (date of death between 12.31-91 al'd 1.1-95) D 11. Election to tax under Sec. 9113(A)(AllachSchO) I- Z W o z o a.. IJ) w 0:: 0:: o l.) THIS SECTION MUST BE COMPLETED. ALL CORRESPONDENCE AND CONFIDENTIAL TAX INFORMATION SHOULD BE DIRECTED TO: NAME COMPLETE MAILING ADDRESS Samuel J. Goncz, Esq. 301 Grant Street, 20th Floor FIRM NAME (If Applicable) Buchanan Ingersoll P.C. Pittsburgh, PA 15219-1410 TELEPHONE NUMBER 412-562-1381 1. Real Estate (Schedule A) (1) 0.00 0.00 0.00 0.00 OFFICIAL USE ONLY 2. Stocks and Bonds (Schedule B) (2) 3. Closely Held Corporation. Partnership or Sole-Proprietorship (3) 4. Mortgages & Notes Receivable (Schedule D) 5. Cash. Bank Deposits & Miscellaneous Personal Properly (Schedule E) (4) (5) 1,758,767.90 z o ~ :3 ::::l t- n: <( o w 0::: 0.00 6. Jointly Owned Properly (Schedule F) (6) o Separate Billing Requested 7. Inter-Vivos Transfers & Miscellaneous Non-Probate Properly (7) (Schedu Ie G or L) 0.00 .J~ .r:- 1,1-1:8,767.90 8. Total Gross Assets (total Lines 1-7) (8) 2,663.46 8.60 9. Funeral Expenses & Administrative Costs (Schedule H) (9) 10. Debts of Decedent. Mortgage Liab"ities. & Liens (Schedule I) (10) 11. Total Deductions (total Lines 9 & 10) (11 ) 2,672.06 12. Net Value of Estate (Line 8 minus Line 11) 13. Charitable and Governmental Bequests/See 9113 Trusts for which an election to tax has not been made (Schedule J) (12) 1,756,095.84 (13) 0.00 14. Net Value Subject to Tax (Line 12 minus Line 13) SEE INSTRUCTIONS ON REVERSE SIDE FOR APPLICABLE RATES (14) 1,756,095.84 15. Amou nt of Line 14 taxable at the spousaltax 1,756,095.84 x .0 ~(15) z rate. or transfers under Sec. 9116 (a)(1.2) 0 i= 16. Amount of Line 14 taxable at lineal rate 0.00 x.O ~(16) ~ I- ::l 0.00 11. 17. Amou nt of Line 14 taxable at sibling rate x .12 (17) ::E 0 0.00 0 18. Amount of Line 14 taxable at collateral rate x .15 (18) X ~ 19. Tax Due (19) ..... 0.00 0.00 0.00 0.00 0.00 20. 0 CHECK HERE IF YOU ARE REQUESTING A REFUND OF AN OVERPAYMENT > > BE SURE TO ANSWER ALL QUESTIONS ON REVERSE SIDE AND RECHECK MATH < < 3W46451.000 Decedent's Complete Address: S1REET ADDRESS 2496 Cope Drive Cumberland CITY I STATE I ZIP Mechanicsburg PA 17055- Tax Payments and Credits: 1. Tax Due (Page 1 Line 19) 2. Credits/Payments A. Spousal Poverty Credit 8. Prior Payments C. Discount (1) 0.00 0.00 0.00 0.00 Total Credits (A + 8 + C) (2) 0.00 3. Interest/Penalty if applicable D. Interest E. Penalty 0.00 0.00 TotallnteresUPenalty (D + E) (3) 0.00 4. If Line 2 is greater than Line 1 + Line 3, enter the difference. This is the OVERPAYMENT. Check box on Page 1 Line 20 to request a refund (4) 0.00 5. If Line 1 + Line 3 is greater than Line 2, enter the difference. This is the TAX DUE. (5) 0.00 A. Enter the interest on the tax due. (SA) 0.00 8. Enter the total of Line 5 + SA. This is the BALANCE DUE. Make Check Pa able to: REGISTEROFWlLLS,AGENT (58) 0.00 PLEASE ANSWER THE FOLLOWING QUESTIONS BY PLACING AN "X" IN THE APPROPRIATE BLOCKS Yes D D D D without receiving adequate consideration? . . . . . . . . . . . . . . . . . . . . . . . . . . .. D 3. Did decedent own an "in trust for" or payable upon death bank account or security at his or her death? D 4. Did decedent own an Individual Retirement Account, annuity, or other non-probate property which contains a beneficiary designation? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " [l[J D IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, YOU MUST COMPLETE SCHEDULE G AND FILE IT AS PART OF THE RETURN. 1. Did decedent make a transfer and: a. retain the use or income of the property transferred;. . . . . . . . . . . . . . . b. retain the right to designate who shall use the property transferred or its income; . c. retain a reversionary interest; or ........................ d. receive the promise for life of either payments, benefits or care? . . . . . . . . . 2. If death occurred after December 12. 1982, did decedent transfer property within one year of death No ~ ~ ~ []I ~ ~ Declaration of preparer other than the personal representative is based on all information of which preparer has any knowledge. SIGNATURE OF PERSON RESPONSIBLE FOR FILING RETURN ~AU~I/'i2~A2~~ ADDRESS DATE "3 J;;'6 Jos . ... PA 17055 ADDRES 301 Grant Pittsburgh, PA 15219 For dates of death on or after July 1. 1994 and before January 1. 1995. the tax rate imposed on the net value of transfers to or for the use ofthe surviving spouse is 3% [72P_S'S9916 (a) (1.1) (i)]. For dates of death on or after January 1. 1995. the tax rate imposed on the net value oftransfers to or tor the use ofthe surviving spouse is 0% [72 P.S. S 9116 (a) (1.1) (ii)] The statute does not exempt a transfer to a surviving spouse from tax. and the statutory requirements for disclosure of assets and filing a tax return are still applicable even if the surviving spouse is the only beneficiary. For dates of death on or after July 1. 2000: The tax rate imposed on the net value of transfers from a deceased child twenty-one years of age or younger at death to or tor the use of a natural parent. an adoptive parent, or a stepparent ofthe child is 0% [72 P.S. S 9116(a)(1.2)]. The tax rate imposed on the net value of transfers to or for the use of the decedent's lineal beneficiaries is 4.5%. except as noted in 72 P.S. S 9116(1.2) [72 P.S. S 9116(a)(1)). The tax rate imposed on the net value of transfers to or for the use ofthe decedent.s siblings is 12% (72 P.S. S 9116(a)(1.3)). A sibling is defined. under Section 9102. as an individual who has at least one parent in common with the decedent, whether by blood or adoption. 3W4646 1.000 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES PO Box 280601 HARRISBURG, PA 17128-0601 September 28,2004 Telephone (717) 787-3930 FAX (717) 772-0412 Butchanan Ingersoll PC One Oxford Centre 301 Grant Street, 20th Floor Pittsburgh, PA 15219-1410 Re: Estate of Virgil F. Puskarich File Number 2104-0045 Dear Sir/Madam: This is in response to your request for an extension of time to file the Inheritance Tax Return for the above estate. In accordance with Section 2136 (d) of the Inheritance and Estate Tax Act of 1995, the time for filing the return is extended for an additional period of six months. This extension will avoid the imposition of a penalty for failure to make a timely return. However, it does not prevent interest from accruing on any tax remaining unpaid after the delinquent date. The return must be filed with the Register of Wills on or before 03/27/05. Because Section 2136 (d) of the 1995 Act allows for only one extra period of six (6) months, no additional extension( s) will be granted that would exceed the maximum time permitted. Sincerely, Claudia Maffei, Supervis,or- Document Processing Unit Inheritance Tax Division .. LAST Wll..L AND TEST AMENT OF VIRGll.. F. PUSKARICH I, VIRGIL F. PUSKARICH, of Cumberland County, Pennsylvania, declare this to be my Last Wlll and revoke any Will previously made by me. ITEM ONE I direct that my remains be cremated and the arrangements be made with the Cremation Society of Pennsylvania. . ITEM TWO I direct that all my just debts, expenses of my last illness, and funeral expenses shall be paid from the assets of my estate,.as soon as practical after my decease, as a part of the administration of my estate. ITEM THREE I bequest any and all motor vehicles and their accessories and equipment, all personal effects and belongings, aIljewelry, clothing and other articles ofhousehold use or ornament and all other tangible personalty of like nature (not including cash and securities), and all insurance policies relating to such property, owned by me at the time of my death to my wife, MARIL YN PUSKARICH, if she survives me for a period of thirty (30) days. Ifsbe predeceases me, I give my said personal property and the insurance thereon to my then living children to be divided among them as they agree. If they cannot agree, then the said personal property shall be sold and the proceeds distributed to them in equal shares. 1 ITEM FOUR Subject to the payments in Item Two, my Personal Representative shall distribute the net income and principal ofall of the remainder of the residue of my estate, including without limitation, all property or interest therein acquired by me or to or which I may become entitled after the execution of this Will, and all property over which I shall have a power of appointment or disposal which i shall not have otherwise exercised, or refused to exercise, to the named Trustees to hold IN TRUST, as part of the Trust Estate of the VIRGIL F. PUSKARICH Family Trust Agreement dated ~ day ofJanuary, 2003, as amended at any time prior to my death, or, if said Agreement is no longer ~ effect, to hold, IN TRUST, on the terms and conditions specified in said Agreement on the date of this Will or of the last Codicil hereto, which like effect as if they were set forth herein verbatim. ITEM FIVE If my wife, MARILYN PUSKARICH, shall die simultaneously with me or there is no sufficient evidence to establish that my wife and I died otherwise than simultaneously, I direct that I shall be presumed to have predeceased my wife, MARIL YN PUSKARICH, notwithstanding any provision of the law to the contrary and that the provisions of my Will shall be construed on such presumption. ITEM SIX I authorize my Executor to claim administrative expenses as a deduction upon my estate return or upon an income tax return or returns as he or it in his or its discretion shall considered to be in the best interests of my beneficiaries, with no duty to make adjustments between income and principal as a result thereof 2 ITEM SEVEN I direct that all estate, inheritance and other taxes in the nature thereof, together with any interest and penalties thereon, becoming payable because of my death with respect to the property constituting my gross estate for death tax purposes, whether or not such property passes under this Will, shall be paid from the principal of my residuary estate, and no person receiving or having a beneficial interest in any such property, whether under this Will or otherwise, shall at any time be required to contribute or to refund any part hereof; PROVIDED, however, that this direction shall not apply to taxes on my property included in my estate solely because of a power of appointment thereover which I possess but have not exercised or on any qualified terminable interest or to any generation skipping transfer. ITEM EIGHT All of my insurance policies which provide indemnity for the loss of any of my personal or real property by fire, windstorm or other similar casualty (mcluding any claim for the loss against any insurance company), I give and bequest, respectively, to those persons or corporations, as the case may be, who shall become the owners of such properties by reason of my death, whether such ownership be acquired under the provisions of this Will, by survivorship or by other means. ITEM NINE Any and all payment or payments of any sum or sums, whether in cash or in kind and whether for principal or income, payable to the said beneficiaries of my estate shall be free from anticipation, assignment, pledge, or obligation of any beneficiary, and shall not be subject to any execution or attachment. 3 ITEM TEN. I appoint my Wife, MARILYN PUSKARICH, Executor of this my last WIll. Should my Wife, MARILYN L. PUSKARICH, fail to qualify or cease to act as Executor, I appoint my daughters, LYNN M. TOSH and LAURA M. PUSKARICH, Co- Executors of this my last Will. I appoint SUELLEN M. WOLFE, attorney of my estate. No bond shall be required of any fiduciary hereunder or in any jurisdiction. No fiduciary hereunder shall have any liability for any mistake or error of judgement made in good faith. ITEM ELEVEN My Personal Representative shall have the following powers in addition to those vested in them by law and by other provisions of my Will, applicable to all property, including property held for minors, whether principal or income, exercisable without court approval, and effective until actual distribution of all property. Such list of powers is not exclusive and it is not meant or intended for the powers hereinafter set forth to be exclusionary and in derogation of any remaining statutory powers; and To retain, any or all property owned by me at the time of my death in the form in which it then exists; acquire by purchase or otherwise or retain, temporarily or permanently, any kind of realty and personalty including stocks and unsecured obligations, undivided interest, interests in investment trusts, mutual funds, legal and discretionary common trust funds, leases, any property belonging to my estate, and property which is outside of my domicile, all without diversification as to kind or amount and without being limited to investments authorized by law for trust funds, (including the discretion to retain as 4 an investment any obligation or obligations owing to me by any corporation in which I have a stock interest at the time of my death) and hold funds uninvested, or deposit any moneys in one or more saVings or other banks in any form of account whether or not interest bearing; and To vote in person or by general, limited or discretionary proxy, with respect to any investments that may be owned by my estate or any trust, or consent to any purpose, in respect of any stocks or other securities; exercise or sell any rights of subscription or other right in respect thereof; and To hold two or more trusts or other funds in one or more consolidated funds, in which the separate trusts or funds shall have undivided interest; and To sell, exchange, or otherwise dispose of realty and personalty publicly or privately, wholly or partly on credit or for any consideration including stocks, bonds or other corporate obligations and grant options for the purpose, exchange or other disposition of any such property; and \ J To pay general legacies, establish trusts, divide or distribute principal, in kind or in money, or partly in each, or by way of undivided interests, even if shares be composed differently; and To delegate discretionary powers to agents, remunerate them, and pay their expenses, employ and pay the compensation of accountants, custodians, legal and investment counsel; and To ~ assign, alter, extend, compromise, release with or without consideration, or submit to arbitration, obligations or claims, including taxes, held by or asserted against them or which affect estate or trust assets; and To hold property in the name of nominees; and To borrow money from themselves or others and pledge or mortgage any.property, for the payment of taxes, debts, legacies or expenses or any other propose which in their opinion will facilitate the administration of my estate or any trust; and 5 To manage, retain, improve, alter, subdivide, develop, dedicate to public use or lease real property or grant easements with respect thereto for periods to begin presently or in the future without regard . to statutory restrictions on leasing and even though any such period may extend beyond the term of any trusts; and To consent to and participate in any plan for the liquidation, reorganization, consolidation Of merger of any corporation and security of which is held; and To abandon, in any way, property which the determine not to be worth pr()tecting; and In connection with the administration of my estate and ofany fund hereunder, I direct that all corporate stock distributions in the stock of the distributing corporation ( except such distribution, whether described as stock dividends, stock splits or otherwise, paid in stock of the distributing corporation, where the number of shares of that class of stock distributed to shareholders of that class amounts to six (6%) percent or less than the outstanding number of shares of that class on the record date for such distribution), all rights to subscribe accruing on or in respect of any securities held hereunder, all capital gains distributions on shares of mutual funds, and all liquidating dividends shall be treated as principal; and all other cash or stock dividends accruing on or in respect of any such securities shall be treated as income; and To make loans out of the trusts to my Executors provided that such loans are made on adequate security and for an adequate interest; and To allocate any portion of my Generation Skipping Tax exemption under Section 263 1 (a) of the Internal Revenue Code, or any similar exemption, exclusion or other benefit allowable under the law in force when I die, to any property as to which I am the transferor, within the meaning of Section 2652(a) of the Internal Revenue Code, including any property transferred during my life, to elect out 6 . of any deemed allocation or revpke any prior election out, and to exercise the special election provided in Section 2652(a)(3) of the Internal Revenue Code as to any part or aU of the Marital Trust under my above mentioned trust; and Notwithstanding any of the other provisions of this Will and the grant ofany power either by . common law, statute or as set forth herein, the Trustees shall not possess or exercise any power, the possession of which could or would in any manner disqualifY the portion of my estate so qualified for the purposes of or with respect to the marital deduction under the federal estate tax laws or under any law of any state which may grant a similar marital deduction and which has proper jurisdiction of my estate upon my death for estate or similar tax purposes; and To join my wife in making a joint income tax or gift tax return or to execute a consent to any gift made by my wife for any fiscal year that included the date of my death or for any period thereto, and in connection therewith, to pay such amounts of tax, interest and penalty as they may deem advisable, even though not attributable entirely to my income or gifts without requiring an indemnification agreement. IN WITNESS WHEREOF, I have signed, sealed, published and declared this to be my Last Will and Testament, consisting of eight pages plus the Acknowledgment and Affidavit, in the presence ofthe persons witnessing it at my request thi~ay of January, 2003. USKARICH 7 ~ L L ~ L L 1,; \......; F. PUSKARICH, the Testator herein, named, as and for his Last Will and Testament in the presence of us, who in his presence, at his request, and in the presence of each other have subscribed our names Jj,g){" /)'fHYt/o-k. Ji~4.;/;7~ Address . 12.- hl" rrt? (J -1-1'- '8'-" () 1i13'.~\}lL/" kw J... /ft- /70 s-o Address ' 0 . ..-'1 \~k......nt It....,,:J~ 6:: . /11 I D Address 8 ,!to !" VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT TIllS AGREEMENT, made thi~d'Y of January, 2003, by and between VIRGil. F. PUSKARICH, of Cumberland County, Pennsylvania, hereinafter called the "Grantor", AND MARILYN PUSKARICH and SUELLEN M. WOLFE, hereinafter called the "Trustee". In the event that MARILYN PUSKARICH or SUELLEN M. WOLFE is unavailable or unable to serve as Trustee, the Co-Trustee shall be MELLON BANK. WITNESSETH WHEREAS, the Grantor has caused his life to be insured tinder certain insurance policies set forth in the "Schedule of Policies" hereto annexed and made a part hereof, which policies have been or hereafter will be made payable to the Trustee. NOW THEREFORE, in consideration of the mutual covenants and agreements herein contained, it is agreed by and between the parties hereto as follows: ARTICLE! Upon the policies included hereunder maturing by reason of the death of the Grantor (or at such later time as may be specified in any policy), the Trustee, upon being notified thereof, shall collect the amounts payable thereunder and shall hold the same as a trust estate along with any other property that may be received from the Grantor's estate, deposited as a part of the trust estate during the Grantor's lifetime or received from any other source. The net income and principal thereof shall be disbursed in the following manner: A. 1. If the Grantor's wife, MARILYN PUSKARICH, survives the Grantor or is presumed 1 to have survived him as hereinafter provided, there shall be established a fund to be known as "Trust A", which shall consist of that fractional share of the trust estate determined as follows: The numerator of the fraction shall be equal to the value of the trust estate reduced by the maximum amount, if any, which will produce a federal taxable estate of a value that, after allowing for the available unified credit and the credit for state death taxes other than those imposed solely for the purpose of obtaining the credit allowed under Section 2011 of the Internal Revenue Code, or its equivalent, will result in no federal estate tax being imposed on the Grantor's estate. The denominator of the fraction shall be equal to the value of the trust estate. Such fractional share of the trust estate shall be determined on the basis finally determined for federal estate tax purposes, shall include only assets that qualify for the marital deduction, assets to the extent possible upon which there is available no foreign death tax credit, and shall be undiminished by any estate, inheritance or other death taxes. 2. The Trustee shall hold this fund as a separate fund for the benefit of the Grantor's said wife and shall pay to her, or expend for her benefit, all the net income therefrom received from. and after the date of the Grantor's death in quarter-annual or more frequent installments for as long as she shall live. In addition, the Trustee shall pay such amounts of the principal from Trust A to the Grantor's said wife as she shall request, up to an including the whole thereot: or in the event the Grantor's said wife is incapacitated and unable to make such request, the Trustee may expend such amounts of principal from Trust A as it, in its sole discretion, may deem necessary for her health, comfort, welfare, maintenance and support. 3. On the death of the Grantor's said wife, Trustee shall distribute the principal of Trust A to and it shall become a part of Trust B herein established, to be continued in trust or distributed as provided herein. 2 b. As to the property over which the child did not have the power to withdraw, or in the event such child failed to exercise the general power of appointment given in subparagraph a above, then all of such property shall be distributed to the issue, per stirpes, of such child then living, or if such child has no living issue then living, then to the issue of the Grantor then living, per stirpes; provided, that if the share of the Grantor's estate is then being held in trust by the Trustee for any such issue, the share herein apportioned shall be added to and fonn a part of the principal of the trust held for the benefit of such issue. S. If none of the Grantor's issue is then living, or if all of the Grantor's issue shall predecease the survivor of the Grantor and his said wife, the Trustee shall divide the principal of the trust estate as then constituted into two (2) equal shares and distribute, outright and free of trusts, said shares as follows: a. One-half (~), hereof. to the Grantor's sister-in-law, PAMELA GODWIN McMAHON; otherwise to her then living issue, per stirpes; b. One-half(~), hereof. to tl:te Grantor's sister, DARLENE BOHNAK. otherwise to her then living issue, per stirpes. D. If any beneficiary entitled to receive a share of principal hereunder shall be under the age of twenty-five (25) years, such share shall not be distributed to him or her but shall be retained by the Trustee hereunder until the beneficiary attains the age of twenty-five (25) years, at which time the principal shall be paid to him or her, free of trust. During such time, the Trustee shall pay the net income from his or her separate share in quarter-annual or more frequent installments, to or for the benefit of such beneficiary. If the Trustee deems the net income to be insufficient to provide for the health, maintenance, support and complete education, including preparatory, college and postgraduate 4 or professional training of such beneficiary, the Trustee may also expend so much of the principal of his or her share as it deems necessary therefor; provided, however, that such distributions of net income and principal may be applied either directly or by making payment to his or her Guardian or other legal representative or to the person with whom he or she resides without liability on the part of the Trustee to see to the application thereof If any such beneficiary shall die before reaching the age of twenty- five (25) years, the property held in trust for him or her, together with any accrued or undistributed income, shall be distributed to the beneficiary's issue then living, per stirpes. If the beneficiary has no living issue then living, the Trustee shall distribute the trust property to the person or persons who would be entitled thereto if the beneficiary had then died intestate and unmarried, seized and possessed thereof and domiciled in the Commonwealth of Pennsylvania. E. Should the principal of any trust hereinbefore created be or become too small in the Trustee's discretion to make the establishment or continuance of the trust advisable, the Trustee may terminate the trust and make immediate distribution of the then remaining trust property to the beneficiary or beneficiaries then entitled to the income of the trust property. The receipts and releases of the distributee will terminate absolutely the right ofall persons who might otherwise have a future interest in the trust, whether vested or contingent, without notice to them and without the necessity of filing an account in any court. In addition, the Grantor specifically exonerates the Trustee from all liability or accountability to any such persons having or claiming a future interest in the trust, whether vested or contingent, with respect to the exercise of the discretionary authority hereinabove granted. 5 ARTICLE TWO All shares of principal and income shall, until actual distribution to the respective beneficiaries, be free from the debts, contracts, alienation and anticipation of any beneficiary or beneficiaries, and the same shall not be liable to any levy, attachment, execution or sequestration. ARTICLE THREE Upon the death of any income beneficiary, any accrued, accumulated or undistributed income held or received by the Trustee shall be paid to the person or persons for whose benefit the principal producing such income is continued in trust or to whom such principal is distributed under the terms hereof. ARTICLE FOUR The Trustee shall receive compensation on the gross income of the trust, and in addition thereto, a reasonable fee based on the market value of the principal of the trust estate, which fee shall be in accordance with the then prevailing rate of compensation charged by the Trustee for like services, such compensation not to exceed that which would be allowed by a court havingjurisdiction over a similar trust. Prior to the funding of the trust created hereunder, the Trustee shall receive no compensation for its services. ARTICLE FIVE The Grantor's Will and other trust agreements created by the Grantor may provide for additions to this trust, and consequently such other instruments should be examined in connection with the making of any alteration, amendment, change, revocation or termination of this trust, or part 6 thereof: to detennine what changes, if any, should be made in such other instrument; and more important, after the Grantor's death, what consequences, ifany, the terms, conditions and provisions of this trust and such other instruments have on the continued existence and operation of each other. ARTICLE SIX The Grantor reserves the right to himself, or to any other person, at any time, and from time to time to add cash, securities or other property to the corpus of the trust estate created herein, by deed, gift, or will; and all such additions shall be held, administered and distributed in accordance with the provisions of this Agreement. ARTICLE SEVEN No amounts of money or property exempt from federal estate tax and received by the Trustee hereunder as a result of my participation qualified pension or profit sharing plan as defined by the Internal Revenue Code, shall be used in any manner to pay taxes attributable to my death, or any of my debts or administrative expenses incurred in administering my estate. ARTICLE EIGHT The Grantor reserves the right and power to amend or revoke this Agreement at any time and from time to time, either in whole or in part, without the consent of the Trustee or any beneficiary hereunder, by written notice to the Trustee to that effect; provided, however, that the duties, responsibilities and rate of compensation shall not be altered or modified without their written consent. 7 Any Trustee shall have tbe right to resign at any time as Trustee upon not less then thirty (30) days written notice to the Grantor, if any, and if not, to the current income beneficiary. Upon the effective date of sucb resignation, all duties of the resigning Trustee shall cease, except for the duty to account and turn over the trust assets. During his lifetime, the Grantor shall have the right, in his sole and absolute discretion, to remove the Trustee at any time, provided, however, that simultaneous with the removal of the Trustee, he shall nominate and appoint a successor Trustee. If any Trustee fails or ceases to serve during the lifetime of the Grantor, the Grantor shall immediately appoint a successor Trustee to fill the vacancy. ARTICLE NINE The Trustee and its successor shall have all the power and authority granted to the Trustees by the State of Pennsylvania; and in addition to any not in limitation thereof they shall have the following powers and authority unrestricted by statute or rules of law regulating investments by Trustees; To retain any and all property owned by the Grantor at the time of the Grantor's death in a form in which it then exists; acquire by purchase or otherwise, and retain, temporarily or permanently, any kind of realty and personalty, including stocks and unsecured obligations, undivided interests, interest in investment trusts, mutual funds, legal and discretionary common trust funds, leases, and other property of Grantor's domicile, all without diversification as to kind or amount and without being limited to investments authorized by law for trusts funds (including the discretion to retain as an investment any obligation or obligations owing to the Grantor by any corporation in which the 8 '. Grantor has a stock interest at the time of the Grantor's death (including any common trust fund administered by the Trustee pursuant to the Uniform Common Trust Fund Act) and hold funds uninvested or deposit any monies in one or more savings or other banks (including the Trustee's or any owned or affiliated with it) in any form of account whether or not income bearing; (provided, however, that non-income producing or unproductive property shall not be retained as an asset of the trust for more than a reasonable time during the lifetime of the Grantor's said wife, or if Grantors said wife shall by written instrument delivered to the Trustee, direct the Trustee to convert any non- income producing property held in the trust estate to income producing property, the Trustee shall within a reasonable time after its receipt comply with the direction); To vote irr person or by general, limited or discretionary proxy, with respect to any investments that may be owned by Grantor's estate or any trust, or consent for any purpose, in respect of any stocks or other rights in respect thereof; To hold two or more trusts or other funds in one or more consolidated funds, in which the separate trusts or funds shall have undivided interests; To sell, exchange or otherwise dispose of realty and personalty publicly or privately, wholly or partly on credit or for any consideration including stock, bonds, or other corporate obligations and grant options for the purpose, exchange, or other disposition of any such property; To pay general legacies, establish trusts, and divide or distribute principal, in kind or in money, or partly in each, or by way of undivided interest, even ifsuch share be composed differently; To delegate discretionary powers to agents, remunerate them, and pay their expenses, employ and pay the compensation of accountants, custodians, legal and investment counselors; To renew, assign, alter, extend, compromise, release, with or without consideration, or to 9 '. submit to arbitration, obligations or claims, including taxes, held by or asserted against or which affect estate or trust assets; To hold property in the name ofa nominee; To borrow money from themselves or others and pledge or mortgage any property, for the payment of taxes, debts, legacies or expenses or for any purpose which in their opinion will facilitate the administration of the Grantor's estate or any trust; To manage, retain, improve, alter, subdivide, dedicate to public use or lease real property or grant easements with respect thereto for periods to begin presently or in the future without regard to statutory restrictions on leasing and even though any such period may extend beyond the term of any trust; To abandon, in any way, property which they determine not to be worth protecting; and In connection with the handling of the Grantor's estate and of any funds held hereunder, Grantor directs that all corporate stock distributions in the stock of the distributing corporation (except such distributions, whether described as stock dividends, stock splits or otherwise, paid in the stock of he distributing corporation, where the number of shares of that class of stock distributed to shareholders of that class amounts to six (6%) percent or less of the outstanding number of shares of that class on the record date for such distribution), all rights to subscribe accruing on or in respect of any securities held hereunder, all capital gains distributions on shares of mutual funds, and all liquidating dividends shall be treated as principal; and all other cash or stock dividends accruing on or in respect of any such securities be treated as income; and To make loans out of the trust estate to the Grantor's Personal Representative, provided that such loans are made on adequate security and for an adequate interest; and 10 . Notwithstanding any of the other provision of this Agreement and the grant of any power either by common law, statute or as set forth herein, the Trustee shall not possess or exercise any power, the possession of which could or would in any way disqualify the portion of Grantor's estate so qualified for the purpose of or with respect to the marital deduction under the Federal Estate Tax Laws or under the laws of any state which may grant a similar marital deduction and which proper jurisdiction the estate of the Settlor upon his death for estate or similar tax purpose. ARTICLE TEN The Trustee may pay to the personal representative of the Grantors estate an amount fr.om the corpus of the trust estate which the said personal representative shall certify as necessary to supplement the Grantor's estate in order to pay funeral expenses, and all bequests, taxes, debts, and expenses of administration or the Trustee may pay the same directly. In consideration of the Trustee delivering any assets held hereunder to the personal representative of the .Grantors estate, the personal representative shall indemnify the Trustee and shall save the Trustee harmless from . liability for any claim that any creditor (whether general creditor or taxing authority) may have against the assets held by the Trustee under this Agreement. ARTICLE ELEVEN The Grantor reserves to himself during his lifetime all payments, dividends, surrender values, rights, benefits, option or privileges of any kind which may accrue on account of any of the policies included hereunder, and the right at any time to change the beneficiary thereof or to assign, pledge or use said policies or any of them, to borrow money thereon or for any other purpose, without 11 . consent, approval or joinder of the Trustee or any beneficiary hereunder. Further, without limiting his rights hereunder, the Grantor reserves the right to withdraw any and all of the policies or other designated benefits subject to this Agreement. It is the intent that this Agreement shall be operative only with respect to the proceeds of such of the policies subject to this Agreement as in terms may be due and payable to the Trustee at the time of the death of the Grantor and thereafter, after deduction of all charges against said policies by way of advances, loans, premiums or otherwise, and the Trustee shall in the absence of express notice of inaccuracy, be protected on accepting as correct the statements and figures of the insurance policies as to the net proceeds of said policies. ARTICLE TWELVE Notwithstanding the powers invested in fiduciaries or by the provisions of this trust, no Trustee acting hereunder, who is also a beneficiary, shall be permitted to participate in any decision or make or withhold distribution hereunder to or for his or her own benefit or to detennine whether the receipt or disbursement shall be allocated to principal or income. No Trustee may participate in any decision to make or withhold distribution hereunder to or for the benefit of any person he or she has a legal liability to support. In such cases, the decision of the remaining Trustee or Trustees shall control. Each Trustee shall have the right at any time to relinquish any power granted to such fiduciary under the provisions of this trust or by law. It is intended that the trust created in Article 1. B. of this document shall not be includable in the taxable estate of my said wife. Therefore, Grantor directs that any rights, powers, duties, authority or discretion given either to any Trustee or my said wife, by any such trust or any other provisions contained herein, or in any amendment hereto, which conflict with this intention or which will result in imposing any death or estate tax: upon or 12 . measured by the corpus of such trust shall be reconciled, revoked or ignored, or any adequate provision shall be so amplified as to accomplish said objective. ARTICLE THIRTEEN The Trustee shall be under no obligation to payor to see to the payment. of premiums, assessments or other charges upon the policies of insurance included hereunder and shall be responsible for the proceeds only when, as and if paid to it, and during the lifetime of the Grantor shall be under no obligation with respect to such policies included hereunder except for the safekeeping of those deposited with the Trustee unless otherwise expressly agreed herein. ARTICLE FOURTEEN The Trustee may render an accounting at any time to the then beneficiaries ofthe trust estate, or the legal or natural guardian of any beneficiary, and the Grantor; and the written approval of such persons shall be final, binding and conclusive upon all persons then or thereafter interested in this trust . for that beneficiary. The Trustee may at any time, but is not required to render a judicial account of its administration of the trust. ARTICLE FIFTEEN It is the intention of the parties hereto that this instrument and all questions as to the construction, validity, effect and administration thereof shall be governed by the laws of the State of Pennsylvania. 13 #' ARTICLE SIXTEEN I t is mutually understood and agreed that this Indenture shall extend to and be obligatory upon the Executors, Administrators, Legal Representatives and Successors, respectively, of the parties thereto. IN WITNESS WHEREOF, the parties hereto have executed this Trust Agreement on this at of January. 2003. /4 f' fk~ G!tANtOR: .' / i ,v r .' r; . f,~ /~I I.," ..-/"/ i '.. ' ()..,[A.."- ~~~~ WITNESS: WITNESS: ~(,.L WITNESS: TRUSTEE: ~t?r)...p--.J~~ l TRUSTEE: 14 . , STATE OF PENNSYL VANIA SS: COUNTY OF DAUPmN On tbis ~ilY of January, 2003, before me, 8 Notary Public, personally appeared VIRGIL F. PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is, subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL ~ 'iF, ~ Nocarr JlWI&c i ~T~. ~.c~ , .. ~~.~ ! ~ Ccmmll3ion ~__), lOO4 Notary Public (SEAL) 15 . ^.....~~--_.~..,.----"""~~_.,--"._-->_._-"- REV.1508 EX + (6-98) COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT SCHEDULE E CASH, BANK DEPOSITS, & MISC. PERSONAL PROPERTY ESTATE OF Virgil F puskarich FILE NUMBER 21 04 0045 Include the proceeds of litigation and the date the proceeds were received by the estate. All property jointly-owned with the right of survivorship must be disclosed on Schedule F. ITEM NUMBER DESCRIPTION VALUE AT DATE OF DEATH 1 American Skandia, One Corporate Drive, Shelton, CT 06484; Annuity Policy #ASXT 349126. Beneficiary is the Estate of Virgil F. Puskarich. 29,853.87 2 Commonwealth of Pennsylvania - payment for unused vacation days. 42,583.92 3 Pennsylvania State Employees Retirement System, 30 North Third Street, Harrisburg, PA 17108. Beneficiary is the Estate of Virgil F. puskarich. 1,567,544.49 4 Pennsylvania State Employees Retirement System, 30 North Third Street, Harrisburg, PA 17108. Deferred compensation. Payable to Estate of Virgil F. Puskarich. 118,785.62 3W46AD 1.000 TOTAL rAlso enter on line 5 Recanitulationl $ (If more space is needed, insert additional sheets of the same sizel 1,758,767.90 REV-1511 EX + (12-99) COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF Virgil F Puskarich SCHEDULE H FUNERAL EXPENSES & ADMINISTRATIVE COSTS FILE NUMBER 21 04 0045 Debts of decedent must be reported on Schedule I. ITEM NUMBER DESCRIPTION AMOUNT A. FUNERAl EXPENSES: 1. Cremation Society of the Patriot 277 . 92 Total from continuation pages 2,385.54 8. ADMINISTRATIVE COSTS: 1. Personal Representative's Commissions Name of Personal Representative(s) Social Security Number(s) I EIN Number of Personal Representative(s) - - Street Address City State Zip Year(s) Commission Paid: 2. Attorney Fees 3. Family Exemption: (If decedent's address is not the same as claimant's, attach explanation) Claimant Street Address City State Zip Relationship of Claimant to Decedent 4. Probate Fees 5. Accountant's Fees 6. Tax Return Preparer's Fees 7. TOTAL (Also enter on line 9, Recapitulation) $ 2,663.46 3W46AG 1.000 (If more space is needed, insert additional sheets of the same size) Schedule H part 1 (Page 2) Estate of: Virgil F Puskarich Item No. Description Amount 2 Fine Arts Studio 79.45 3 Franklins, thank you cards 140.19 4 Laura Puskarich -reimbursement for urn 100.00 5 Malpezzi Funeral Home 1,000.00 6 Memorial Service, 2 pastors, soloist, organist, secretary, and a custodian 535.00 7 PCN tape of House of Representatives Eulogy 48.76 8 Postage 45.00 9 Pro Am Video 113.05 10 Stephenson's Flowers 196.09 11 Tribune Review 128.00 Total (Carry forward to main schedule) 2,385.54 REV-1512 EX + (12-03) COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF Virqil F Puskarich SCHEDULE I DEBTS OF DECEDENT, MORTGAGE LIABILITIES, & LIENS FILE NUMBER 04 21 0045 Report debts incurred by the decedent prior to death which remained unpaid as of the date of death, including unreimbursed medical expenses. ITEM NUMBER DESCRIPTION VALUE AT DATE OF DEATH 1. Central Pennsylvania Hematology and Oncology 8.60 3W46AH 2.000 TOTAL (Also enter on line 10. Recapitulation) $ (If more space is needed. insert additional sheets of the same size) 8.60 REV-1513 EX + (9-00) COMMONWEALTH OF PENNSYlVANIA INHERITANCE TAX RETURN RESIDENT DECEDENT SCHEDULE J BENEFICIARIES ESTATE OF Virgil F. Puskarich I. NAME AND ADDRESS OF PERSON(S) RECEIVING PROPERTY TAXABLE DISTRIBUTIONS [include outright spousal distributions, and transfers under Sec. 9116 (a) (1.2)] 1. Marilyn puskarich 2996 Cope Drive Mechanicsburg, PA 17055 NUMBER FILE NUMBER 21 04 0045 RELATIONSHIP TO DECEDENT Do Not List Trustee(s) AMOUNT OR SHARE OF ESTATE 1,756,095.84 ENTER DOLLAR AMOUNTS FOR DISTRIBUTIONS SHOWN ABOVE ON LINES 15 THROUGH 18, AS APPROPRIATE, ON REV-1500 COVER SHEET II. NON-TAXABLE DISTRIBUTIONS: A. SPOUSAL DISTRIBUTIONS UNDER SECTION 9113 FOR WHICH AN ELECTION TO TAX IS NOT BEING MADE 1. B. CHARITABLE AND GOVERNMENTAL DISTRIBUTIONS 1. TOTAL OF PART II - ENTER TOTAL NON-TAXABLE DISTRIBUTIONS ON LINE 13 OF REV-1500 COVER SHEET $ (If more space is needed. insert additional sheets of the same size) STfPA42021F.14 0.00 EST A TE OF VIRGIL F. PUSKARICH FILE No. 21-04-0045 P A INHERITANCE TAX RETURN SCHEDULE J EXPLANATION OF ESTATE DISTRIBUTION The Decedent died on January 4,2004, a domiciliary of Cumberland County, Pennsylvania. He was employed by the Commonwealth of Pennsylvania from 1971 through the date of his death. As an employee, he participated in the State Employees Retirement System ("SERS") and also elected to participate in a SERS Deferred Compensation Plan. Under the terms of SERS, an amount equal to the present value of a participant's accrued benefit is payable in the form of a single lump sum to the participant's designated beneficiary in the event the SERS participant dies while an active participant in SERS. The Deferred Compensation Plan similarly provides that a participant's account balance is payable to the participant's designated beneficiary upon the death of the participant. Both SERS and the Deferred Compensation Plan provide, in accordance with the relevant Pennsylvania statute, with respect to SERS, and Section 2.05 ofthe Plan document, with respect to the Deferred Compensation Plan, that in the absence of a valid beneficiary designation, the lump sum payments are to be made to the participant's estate. The Decedent's most recent beneficiary designation on file with SERS designated the "Virgil F. Puskarich Family Trust Agreement dated 1/23/97," which was a revocable trust agreement (the "1997 Trust Agreement"), as the beneficiary of the Decedent's interests in said Plans. The beneficiary designation on file with respect to the Deferred Compensation Plan also designated the 1997 Trust Agreement as the beneficiary ofthe Decedent's interest in the Deferred Compensation Plan. The Decedent did in fact execute the 1997 Trust Agreement but later revoked it. Specifically, on January 2,2003, the Decedent created the Virgil F. Puskarich Family Trust Agreement ("2003 Family Trust Agreement"), and on January 3,2003, executed a new Last Will and Testament ("Will"). At such time, in accordance with written instructions he received from his then-attorney, the Decedent destroyed the 1997 Trust Agreement and his prior will, thereby revoking the same. As a result of the Decedent's revocation ofthe 1997 Trust Agreement, no valid beneficiary designation existed with respect to the Decedent's accounts in SERS and the Deferred Compensation Plan and, accordingly, such amounts were made payable to the Decedent's estate pursuant to applicable Pennsylvania law and the relevant provisions of the Deferred Compensation Plan document. Articles Two and Three ofthe Decedent's Will provide for the payment of his debts, administration expenses, and funeral expenses, and a bequest of his personal effects. Article Four then provides a residuary bequest of the remaining Estate property to the 2003 Family Trust. The 2003 Family Trust Agreement, in turn, provides for the establishment of two trusts ("Trust A" and "Trust B"), to provide for the benefit ofthe Decedent's widow, Marilyn Puskarich, during her lifetime. Upon Mrs. Puskarich's death, the remaining trust property is then made distributable to various beneficiaries named in the 2003 Family Trust Agreement. Specifically, the remaining property ofthe Trusts would be distributable to the Decedent's then-living issue, per stirpes. See Trust Agreement, Articles I(A)(3) and I(C). The Decedent was survived by two children, Lynn Tosh and Laura Puskarich, and two grandchildren, Anabelle Tosh and Clara Tosh, who are the children ofLynn Tosh. Ifboth ofthe Decedent's daughters are then living, one-half of such property would be distributable to each such daughter. The share of any such daughter who is then deceased would be distributable to her then living issue, per stirpes, or if she has no then-living issue, to the Decedent's other living issue in the same manner. See id. If the Decedent has no then-living issue, the remaining trust property would be distributable one-halfto Pamela Godwin McMahon, or if she is not then living, then to her then- living issue, per stirpes, and one-half to Mrs. Puskarich's sister, Darlene Bohnak, or if she not then living, then to her then-living issue, per stirpes. See Trust Agreement, Article I(C)(5). Thus, as a general matter, each individual beneficiary's interest in the property held under the Trust Agreement is contingent upon the deaths of other beneficiaries who are more closely related to the Decedent and Mrs. Puskarich. Within nine months after the Decedent's death, all of the beneficiaries disclaimed their interests under the 2003 Family Trust Agreement, causing it to be void under Pennsylvania law. Copies oftheir disclaimers follow this statement. Thus, the residuary bequest to the 2003 Family Trust failed, and the residue of the Decedent's estate passed by operation oflaw to his intestate heirs. See 20 Pa. C.S.A. ~ 2101(a). As stated above, the Decedent was survived by his wife, two daughters, and two grandchildren. His parents did not survive him. Each of the Decedent's issue disclaimed his or her interest in the Decedent's estate, leaving Mrs. Puskarich as his sole remaining intestate heir and, thus, sole beneficiary of the Decedent's estate, including his SERS and Deferred Compensation Plan interests. See 20 Pa. C.S.A. ~~ 2102-03. Each disclaimer was a valid disclaimer under Pennsylvania law. Each disclaimer was made in writing. Within nine-months after the Decedent's death, the disclaimers ofthe beneficial interests under the Trust Agreement were filed with the Trustees, and all disclaimers were filed with the Register of Wills of Cumberland County, Pennsylvania.! I It should be noted that none of the Decedent's accrued benefits under SERS or the Deferred Compensation were not distributed at any time to Decedent, Mrs. Puskarich, the Estate or any other person, prior to the execution of the disclaimers. #!72552!-v2 Estate of Virgil F. Puskarich File No. 21-04-0045 Index of Disclaimers 1. Disclaimer of Marilyn Puskarich (Trust Interests) 2. Disclaimer ofLynn M. Tosh (Estate Interests) 3. Disclaimer ofLynn M. Tosh (Trust Interests) 4. Disclaimer of Laura M. Puskarich (Estate Interests) 5. Disclaimer of Laura M. Puskarich (Trust Interests) 6. Disclaimer of Cynthia D. Bohnak, Executrix ofthe Estate of Darlene Bohnak (Trust Interests) 7. Disclaimer of David Bohnak (Trust Interests) 8. Disclaimer of Cynthia D. Bohnak, (Trust Interests) 9. Disclaimer of Pamela Godwin McMahon (Trust Interests) 10. Disclaimer of David J. Gaskell (Trust Interests) 11. Disclaimer of Theodore James Gaskell (Trust Interests) 12. Disclaimer of Stephen J. Gaskell (Trust Interests) 13. Disclaimer of Michael Scott Gaskell (Trust Interests) 14. Disclaimer ofLynn M. Tosh as Co-Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell (Estate and Trust Interests) 15. Disclaimer of Laura M. Puskarish as Co-Guardian ofthe Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell (Estate and Trust Interests) #!725344-v! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DNISION INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. ) ..-.,~. 04-004:~"' " d ~ v'J t""'i1 W ..... --.J DISCLAIMER - ::::::~ ........ . . ;",.__ 1\..JJ ~;~:;. WHEREAS, VIRGILF. PUSKARlCH (the "Decedent") di6don Jani:HU)' 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, the Decedent's wife, MARn.YN PUSKARICH, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"), but not her intestate rights in the Trust Property, to the extent the Trust Property may otherwise be distributable to the Decedent's intestate heirs; and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise; provided, however, that the undersigned does not disclaim her intestate rights in the Trust Property, to the extent the Trust Property may otherwise be distributable to the Decedent's intestate heirs. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her he' , personal representatives and assigns. /' 'X ,Witness /" 72.L1Jf(. ~~.~ Witness ./ '. ~'f2~~~ MARIL PUSKARlCH UpAAL- //), ::200'</ Date 2 COMMONWEALTH OF PENNSYLVANIA COUNTYOF Cu~erk1'lrj ) ) ) SS: On this, the /5 day of #Prl/' , , 2004, before me a notary public, the undersigned officer, personally appeared MARILYN PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. o/~~-4~~ ./ . otary Public -> Notarial Seal . . Jay M. ZiI'TllTlelman, Notary Public ~ ~ ~wp.. Cumbel1and Coun. ty I My Commissiori Expires Mar. 16, ?r- ,~ Member, Pennsylvania Associatr. - . . . :;..;._::a~h;.;rl <. ;; i\lotariea 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ORPHANS' COURT DNISION INRE: ESTATE OF VIRGIL F. PUSKARICH, Deceased ) ) No. ) ("... 04-0045' d ~ C/1 rn u --.I DISCLAIMER ;5. (~,,') WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on JanUiry 4,2004, domiciled in Cumberland County, Pennsylvania, leaving his last Will, dated January 3,2003 (the "Will"); and WHEREAS, the Will was duly probated in the Office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, after providing for the disposition of the Decedent's remains, the payment of his debts, expenses, and taxes, and a bequest of his tangible personal property, the Will bequeaths the residue of the Decedent's Estate to the trustees of the Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"), for further distribution and administration thereunder; and WHEREAS, all beneficiaries of the Trust Agreement have disclaimed, or have announced that they will disclaim, their interests thereunder; and WHEREAS, the Trust Agreement makes no provision for such a contingency and, as a result, Pennsylvania law would require the trustees to reconvey to the Decedent's Estate all property held, or receivable, under the Trust Agreement; and WHEREAS, the Will makes no provision for the disposition ofa portion of the Estate's residue that is disclaimed; and WHEREAS, accordingly, under Pennsylvania law, the disclaimed property is distributable to the Decedent's intestate heirs; and WHEREAS, the Decedent's putative intestate heirs are his wife, MARILYN PUSKARICH, and their two adult daughters, LYNN M. TOSH and LAURA M. PUSKARICH; and WHEREAS, the undersigned, being one of such daughters, is desirous of disclaiming all right, title and interest in and to the property distributable to the Decedent's intestate heirs as a result of the Decedent's death (sometimes referred to herein as the "Intestate Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Intestate Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Intestate Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Intestate Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. 2 It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personaJ..-representatives and assigns. Wi L O~~J2 tql:jr~ Date 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF C-"'uI'rlJC'r~nc-/ ) ) ) SS: On this, the /5 day of /2,rJ / , , 2004, before me a notary public, the undersigned officer, personally appeared LYNN M. TOSH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. fr~~~P:~ Notarial Seal Jay M. ZJmmerman. Notary Public Up Allen Twp.. CumbeIland Cc:llI'4Y My CommLssiOn Expires Mar. 16,2006 ~. ~AssociaIion 01 NoIaries #152l647-vl ;PGHl_ General; 4 IN THE COURT OF COMMON PLEAS OF CillvfBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION d .c,. IN RE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. 04-0045 ) (/} ," u -J ~ --> DISCLAIMER (,~ --' WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Lynn M. Tosh, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et seq. and a qualified disclaimer as defmed in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, J:!e sonal representatives and assigns. ~' f)~J; . /)/\fl; \.',t -kL J V"^ V.:, UVV '/ LYnn_ . Tosh ~, Ie; iJlXlt Date 2 COMMONWEALTH OF PENNSYLVANIA 5'fAIFUITf1LO!tiDA COUNTY OF C vlJ?j)(~rkfJf'/ ) ) ) SS: On this, the /...5"" day of /f:y-f / , 2004, before me a notary public, the undersigned officer, personally appeared LYNN M. TOSH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~jv~~ ~ / . Notary Public Notarial Seal Jay M. Zirnl'nem18". NotarY ~ Yl3I* Allen Twp., CumI:lelIand 2006 Mv QommIssIon ExpireS Mar. 16, . ~.~~OINot81le1 #1 529684-v1 ;PGHl_ General; 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: ESTATE OF VlRGIL F. PUSKARICH, Deceased ) ) ) N 04-0045 :~. o. s? --- ,/) '" u DISCLAIMER ,"" 23: WHEREAS, VlRGIL F. PUSKARICH (the "Decedent") diedol.1 Jan\l?rIY 4, 2()0:4, , '..,....... '..... domiciled in Cumberland County, Pennsylvania, leaving his last Will, dated January 3, 2003 (the "Will"); and WHEREAS, the Will was duly probated in the Office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, after providing for the disposition of the Decedent's remains, the payment of his debts, expenses, and taxes, and a bequest of his tangible personal property, the Will bequeaths the residue of the Decedent's Estate to the trustees of the Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"), for further distribution and administration thereunder; and WHEREAS, all beneficiaries of the Trust Agreement have disclaimed, or have announced that they will disclaim, their interests thereunder; and WHEREAS, the Trust Agreement makes no provision for such a contingency and, as a result, Pennsylvania law would require the trustees to reconvey to the Decedent's Estate all property held, or receivable, under the Trust Agreement; and WHEREAS, the Will makes no provision for the disposition of a portion of the Estate's residue that is disclaimed; and WHEREAS, accordingly, under Pennsylvania law, the disclaimed property is distributable to the Decedent's intestate heirs; and WHEREAS, the Decedent's putative intestate heirs are his wife, MARILYN PUSKARICH, and their two adult daughters, LYNN M. TOSH and LAURA M. PUSKARICH; and WHEREAS, the undersigned, being one of such daughters, is desirous of disclaiming all right, title and interest in and to the property distributable to the Decedent's intestate heirs as a result of the Decedent's death (sometimes referred to herein as the "Intestate Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Intestate Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Intestate Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Intestate Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death ofllie Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. 2 The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver ofthe right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. -- r I) Ii ~. . ~ '-Ll<:-O'- ,-'.- '<./ Witness ~\~d.lA ~ess i-\ Llt1.ulf~! \. 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DMSION INRE: VIRGIL F. PUSKARlCH FAMILY TRUST AGREEMENT ) ) No. ) _ J r2 04-004.5 C,/J rrl -\:I --.J DISCLAIMER ~ --" f,~,0 --' WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4, 2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Laura M. Puskarich, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 620l et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. ~ "I; '- --::\:J -J_,~,(J \..,-L.Q/ jitn:SS - l~ tness ( (;~ ~/...: - :1-.. :t.f Y / / Ii !r) L/ Date I 0r-\\\~(j '-. 2 3 COMMONWEALTH OF PENNSYLVANIA , I'il)., I PH' t,' ,J -~ ,'I' Jt.'l.-J ~ j' COUNTY OF ) ) ) SS: ,/ .J.h 1-"' On this, the z'L; , day of '--j'j..)ei ! I , 2004, before me a notary public, the undersigned officer, personally appeared LAURA M. PUSKARICH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. J } " / ,) I' '. . , ,', i f Lc' ; ,} I ' " ..' ) f ( I ,./././... ',- (, . ,{LLl.L(..'~ U NotaryPublic U Notarial Seal I.ower~ WItiay, NotaIy Plblic Twp., 0aupIWl Ccuty My Cclml..1bQu, , Expires Mer. 14,2006 Member. Pennsytvan;a Association Of Notaries 4 refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither she nor the Estate is now insolvent and neither was insolvent at the date of death of the Decedent, that neither she nor the Estate has made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and neither she nor the Estate has made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that neither she nor the Estate has accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. S 6201 et seq. and a qualified disclaimer as defined in Section 2S 18 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the Estate, its successors and assigns. ~ ~l~~\~ Cyn . aD. Bqhnak Executrix, Estate of Darlene Bohnak s/sA 1 Date Witness Witness 2 STATE OF fLORID~tvrJ~f( V&.--Jt4) COUNTY OF tv ~ l\J61utJ ) ) ss: On this, the S-'-PLday of ~, 2004, before me a notary public, the undersigned officer, personally appeared CYNTHIA D. BOHNAK, the executrix of the estate of Darlene Bohnak, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. rHot~~ Notarial Seal , Lena A. Greenfield, NotaI'I Pubtlc 1 Bentleyville 8oro, Washington Countl My Commission Expires May 27, 2005 I Member, Penr.sy!VaniaAssocieiioil ctf'.lot:ui3S #1 529928-vl ;PGHI_General; 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. ) 04-0045 ,...~. ~.1 DISCLAIMER d ..:::". C/'j 0, WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4;:2004, . ..... '....; domiciled in Cumberland County, Pennsylvania; and ~- .-.- WHEREAS, during his lifetime, the Decedent established that certain V~l F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, David Bohank, is granted certain interests if he survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention ofthe undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 620l et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. , This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. 0-~ ;0/ ~ Witness 0--~--o 'I Date Witness 2 cz.: ~' STATEOF~ COUNTY OF ~ ) ) ) SS: On this, the 5" f.,. day of 1'-1 1 ,2004, before me a notary public, the undersigned officer, personally appeared DAVID BOHNAK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS \\.'HEREOF, I hereunto set my hand and official seal. ~)j . NOtary~ Notarial Se-~ A...~~ Greenfield, Notary Public My~;..~!....,Il.e I?oro, ~ashington County ,",uIIIITlISSlOn EXpires May 27, 2005 MentIer. PennsylvaniaA..."SOCiation otNote!i9S #1529918-vl ;PGHI_ General; 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) ) 04-0045 No. ~ ;-., ~J~. _,' ~T d .:::,. DISCLAIMER (/) 1'-, W -.. --J. WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on J~ary 4,2004, -..... domiciled in Cumberland County, Pennsylvania; and (~:, -.. WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Cynthia D. Bohank, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title artd interest in artd to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that she is not now insolvent and was not insolvent at the date of death of the Decedent, that she has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that she has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. ~y Witness , ~ R"' _ ~"~.. CYnt D. Bohank t~ ~ 5""1 u",y Date Witness 2 ;l STATE OF ~A COVN1YOF ~h ) ) ) SS: On this, the )1~ day of (1,1 ' 2004, before me a notary public, the undersigned officer, personally appeared CYNTHIA D. BOHNAK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~)Jd;M Notary Pub c r Notarial Seal Lena A. Greenfield, Nolary Publk: ~ Bentleyville Bom, Washington COtC1:-j t My Commission Expires May 27. 20(;5 j Member. penr.3y!v2f~;a.4sso(:!ation cfNo':s::T:i- #1 529908-vl ;PGHI_General; 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION d ~ IN RE: VIRGIL F. PUSKARlCH F AMIL Y TRUST AGREEMENT ) ) No. 04-0045 ) V? ill U -"' -.l -- ~ (.j 1'0 DISCLAIMER WHEREAS, VIRGILF. PUSKARICH (the "Decedent") died on January 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Pamela Godwin McMahon, is granted certain interests if she survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing her interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. STATE OF FLORIDA ) ) SS: COUNTY OF ~re\Jc:a.."'~ ) On this, the / '5 day of A-pr.~ L , 2004, before me a notary public, the undersigned officer, personally appeared PAMELA GODWIN McMAHON, .kno""u to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. rlr~4 Notary P ic O VIRGINIA L WRIGHT . MY COMMISSION /I CC 999298 . EXPIRES: Feb 5, 2005 '~AAY Fl. Nouwy Service & ~ Inc. #1 5222S4-vl ;PGHI_ General; 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DNISION ~,""'-' ;.:..J \ _ INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. 04-0045 ) d .J::::,. (/1 M -;::; -> ~~..J DISCLAIMER ~ .~ i,........l t".J WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2, 2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Daniel J. Gaskell, is granted certain interests ifhe survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. S 6201 et seQ. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. - /-\ J .re"! ;., "tC\ K<\.J....\./.. Witness D ~,,~ Ll 4~ .' Date ~ ..r-~'. . .C;'; -, - h<:;) ~1\::! ~tiV\aJ \...rWltness' . 2 STATE OF SOUTH CAROLINA COUNTYOF C Y' 'L-I11 1--7 " J /e ) ) ) ss: On this, the ---L!-dayof ~ft i / ,2004, before me a notary public, the undersigned officer, personally appeared DANIEL J. GASKELL, mown to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set myha..l1d and official seal. ~Y23~/ Notary Publi #1 529246-vl- 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DMSION INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) No. 04-0045 ) d ~. C/.l n-I w -..J -- ....:,........ DISCLAIMER \..JJ N WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, mown as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Theodore James Gaskell, is granted certain interests ifhe survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et ~ and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. ./1 J~>/ ,/ ,.,./ /l!:/~....,~:.,,""''''''o#.' Witness~:'/ ~t Xfu~o(Lv6/ Itnes b~~ ~~~ _~~ Theodore J~ Gaskell . LL /23/2 f:P ~ Date 2 STATE OF FLORIDA COUNTY OF DU.\lPrL ) ) ) SS: On this, the 2~7'" day of 4~/E'/ c... , 2004, before me a notary public, the undersigned officer, personally appeared THEODORE JAMES GASKELL, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. . IN WITNESS WHER EOF, ! hereunto set myhand and0fficiai st:ai. Y~i1~ ~~;r7J~ Notary Public PERSONAlLY KNOWN X OR PROVIDED 1.0. YG6 lYPE OF I.D. ~ OL- ..."..~ "", ...r~ RONALD H. NESlER " :~ MY COMMISSION. DO 134496 . ~ EXPIRES: July 16, 2006 &onded. Thtu NotaIy PIA>Iie UIldlllwr1IerI 3 #1 529203-vl- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: VIRGIL F. PUSKARICH FAMILY TRUST AGREEMENT ) ) ) ...._,. - ;:-..:1. .. d ~ No. 04-0045"::i W 1"'1 -0 --' -J DISCLAIMER ;::: \~ WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on Janl11rry 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Stephen J. Gaskell, is granted certain interests if he survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. ~ 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. '-.. ~/4 '4k . liv?\.) ~.1: . SiepIfn . Gaskell 01-~o-o4 Date 2 STATE OF FLORIDA 0(1# i.-s ) ) SS: ) COUNTY OF ~ On this, the JO day of .4 r (~ t , 2004, before me a notary public, the undersigned officer, personally appeared STEPHEN J. GASKELL, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF. I hereunto set my hand and official seal. / 1..'/ ~(J .r ; /t y Notary Public .~~ Juliana Lima i ..~ Commission # 00301791 .'~ar~ Expires March 21. 2008 'ElII' BondIldTlll\' FaIn.lnIuranc:6.lnc. eoo.385-7019 # I 529220.v I.Disclaimer _' 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DMSION ~. INRE: VIRGIL F. PUSKARlCH FAMILY TRUST AGREEMENT ) ) ) d J;::,. N 04-004SH o. r/J rn -c' -' -.J 2 DISCLAIMER I~~J N WHEREAS, VIRGIL F. PUSKARlCH (the "Decedent") died on January 4,2004, domiciled in Cumberland COlmty, Pennsylvania; and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement, dated January 2,2003 (the "Trust Agreement"); and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which the undersigned, Michael Scott Gaskell, is granted certain interests ifhe survives the Decedent; and WHEREAS, the undersigned did, in fact, survive the Decedent; and WHEREAS, the undersigned is desirous of disclaiming all right, title and interest in and to the property otherwise distributable to the Trusts and under the Trust Agreement (sometimes referred to herein as the "Trust Property"); and WHEREAS, the undersigned has not accepted any interest in or benefit from the Trust Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing his interest in the Trust Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Trust Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that he is not now insolvent and was not insolvent at the date of death of the Decedent, that he has not made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and has not made any sale or other disposition of any interest in the property being disclaimed pursuant to judicial process or otherwise. The undersigned further acknowledges, represents and certifies that he has not accepted property or an interest in the property described above, or any of its benefits. . ..It .IS the specific intention ofth,~ undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. 26201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, his heirs, personal representatives and assigns. /i'~_J.~ Michael Scott Gaskell t//9/"CLl Dat I 2 STATE OF NEW JERSEY ) ) ) SS: ~~ fA (JL~.I . On this, the I q /" day of ~' 2004, before me a notary public, the undersigned officer, personally appeared MICHAEL SCOTT GASKELL, known to me (or COUNTY OF satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the pmposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (J~~~ Notary bhc #1529233-vl- 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DNISION f-J (~ 2! d ~ IN RE: VIRGIL F. PUSKARICH ) F AMIL Y TRUST AGREEMENT ) ) N 04-0045 o. (/.i .-r"J -0 -.. -..J ..~. --- DISCLAIMER I.~....J --' WHEREAS, VIRGIL F. PUSKARICH (the "Decedent") died on January 4,2004, domiciled in Cumberland County, Pennsylvania; and WHEREAS, the Decedent's Last Will and Testament dated January 3, 2003 ("Will") was duly probated in the office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, the Decedent's granddaughters, Annabelle Tosh and Clara Tosh, who are minors, have certain interests in the Decedent's estate ("Estate"); and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement dated January 2,2003 ("Trust Agreement") and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which minor beneficiaries Annabelle Tosh, Clara Tosh and Miyabi Gaskell are granted certain contingent interests; and WHEREAS, the undersigned, by Order of the Orphans' Court, Orphans' Court Division, Court of Common Pleas, Cumberland County, Pennsylvania, in the matter captioned In Re: Estate of Virgil F. Puskarich, deceased, No. 04-0045, has been appointed a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell with respect to the interests of said minors in the property of the Estate and the Trusts, as the case may be (sometimes referred to herein collectively as the "Property"); and WHEREAS, the undersigned, in her capacity as a Guardian of, and with respect to, the interests of Annabelle Tosh, Clara Tosh and Miyabi Gaskell in the Property, has been authorized by said Order of the Orphans' Court to disclaim the Property on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell; and WHEREAS, the undersigned, on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, is desirous of disclaiming all of their right, title and interest in and to the Property; and WHEREAS, neither the undersigned, nor anyone else acting on behalf of Annabelle Tosh, Clara Tosh or Miyabi Gaskell, has accepted any interest in or benefit from the Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing said Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned, on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither Annabelle Tosh, Clara Tosh, nor Miyabi Gaskell is now insolvent or was insolvent at the date of death of the Decedent, that no such person has made any voluntary assignment or transfer of, contract to assign or transfer, or encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and no such person has made any sale or other disposition of any interest in the Property pursuant to judicial process or otherwise. The undersigned, in her capacity as a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, further - 2 - acknowledges, represents and certifies that no such person has accepted the Property or an interest in the Property as described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. 96201 et~. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned. her heirs. personal representatives and assigns. . L strk~Y1be.r ''l,;2ttJ- Date OMMONWEAL TH OF PENNSYLVANIA Notarial Seal KiIK M. Wrse. Notary Public Upper Allen Twp., Cumberland Counly My Commission Expires Feb. 7, 2008 Member. Pennsylvania Association Of Notaries - 3 - # 1608523-v 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: VIRGIL F. PUSKARICH ) FAMILY TRUST AGREEMENT ) ) N 04-0045 o. d ~,- C/J rn u DISCLAIMER -..J :L"":? WHEREAS, VIRGil.- F. PUSKARlCH (the "Decedent") died on J<iIlllary 4,~04, \..0 domiciled in Cumberland County, Pennsylvania; and WHEREAS, the Decedent's Last Will and Testament dated January 3,2003 ("Will") was duly probated in the office of the Register of Wills of Cumberland County, Pennsylvania; and WHEREAS, the Decedent's granddaughters, Annabelle Tosh and Clara Tosh, who are minors, have certain interests in the Decedent's estate ("Estate"); and WHEREAS, during his lifetime, the Decedent established that certain Virgil F. Puskarich Family Trust Agreement dated January 2,2003 ("Trust Agreement") and WHEREAS, the Trust Agreement provides for the creation and funding of two trusts, known as "Trust A" and "Trust B" (collectively, the "Trusts"), in which minor beneficiaries Annabelle Tosh, Clara Tosh and Miyabi Gaskell are granted certain contingent interests; and WHEREAS, the undersigned, by Order of the Orphans' Court, Orphans' Court Division, Court of Common Pleas, Cumberland County, Pennsylvania, in the matter captioned In Re: Estate of Virgil F. Puskarich, deceased, No. 04-0045, has been appointed a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell with respect to the interests of said minors in the property of the Estate and the Trusts, as the case may be (sometimes referred to herein collectively as the "Property"); and WHEREAS, the undersigned, in her capacity as a Guardian of, and with respect to, the interests of Annabelle Tosh, Clara Tosh and Miyabi Gaskell in the Property, has been authorized by said Order of the Orphans' Court to disclaim the Property on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell; and WHEREAS, the undersigned, on behalf of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, is desirous of disclaiming all of their right, title and interest in and to the Property; and WHEREAS, neither the undersigned, nor, anyone else acting on behalf of Annabelle Tosh, Clara Tosh or Miyabi Gaskell, has accepted any interest in or benefit from the Property and has neither received nor shall receive any consideration in money or monies worth for disclaiming and renouncing said Property. NOW, THEREFORE, intending to be legally bound hereby, the undersigned, on behalf of Annabelle rosh, Clara Tosh and Miyabi Gaskell, does hereby irrevocably, and without qualification, disclaim, renounce and refuse to accept any and all right, title and interest in and to the Property, whether the same arises under the laws of the Commonwealth of Pennsylvania or otherwise. The undersigned acknowledges, represents and certifies that neither Annabelle Tosh, Clara Tosh, nor Miyabi Gaskell is now insolvent or was insolvent at the date of death of the Decedent, that no such person has made any voluntary assignment or transfer of, contract to assign or transfer, or 'encumbrance of, given a written waiver of the right to disclaim the succession to and interest in, and no such person has made any sale or other disposition of any interest. in the Property pursuant to judicial process or otherwise. The undersigned, in her capacity as a Guardian of the Estates of Annabelle Tosh, Clara Tosh and Miyabi Gaskell, further - 2- acknowledges, represents and certifies that no such person has accepted the Property or an interest in the Property as described above, or any of its benefits. It is the specific intention of the undersigned that this Disclaimer constitute a disclaimer under 20 Pa. C.S.A. S 6201 et seq. and a qualified disclaimer as defined in Section 2518 of the Internal Revenue Code of 1986, as amended, or the corresponding provisions of any subsequent federal tax law, to be filed, recorded and delivered as required by said statutes, and that the provisions of this Disclaimer shall be interpreted to give full effect to said intention. This instrument shall be immediately effective and shall be binding upon the undersigned, her heirs, personal representatives and assigns. n~_ 0'r" Witnes ~Mb~ Date , '3 2ro~ I COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary J. Gouffer, Notary Public Silver Spring Twp., Cumberland County My Commission Expires Nov. 17, 2007 Member. Pennsylvania Association Of Notaries - 3 - ! '-., .:-j-..) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE NOTICE OF DETERMINATION AND 'ASSESSMENT OF PENNSYLVANIA ESTATE TAX BASED ON FEDERAL ESTATE TAX RETURN DATE ESTATE OF DATE OF DEATH FILE NUMBER COUNTY ACN *' BUREAU OF INDIVIDUAL TAXE$. INHERITANCE TAX DIVISION PO BOX 280601 HARRISBURG PA 17128-0601 REV-483 EX AFP (03-05) , (.; 07-12-2005 PUSKARICH 01-04-2004 21 04-0045 CUMBERLAND 201 AItoLmt R..l tt.d VIRGIL F 1r>lr:, " v" SAMUEL J Got!g!l;"lrSQ BUCHANAN INGERSOLL 301 GRANT ST 20TH FL PGH PA 15219 MAKE CHECK PAYABLE AND REMIT PAYMENT TO: REGISTER OF WILLS CUMBERLAND CO COURT HOUSE CARLISLE, PA 17013 NOTE: To insure proper credit to your account, submit the upper portion of this for. with your tax payment. CUT ALONG THIS LINE ~ RETAIN LOWER PORTION FOR YOUR FILES ~ ~~:'~~I.A1!~.11JJ:~7......ii.Ab~e~15~.1n!~IJDrrlbll.AlDS.A~~~~~,"............................ OF PENNSYLVANIA ESTATE TAX BASED ON FEDERAL ESTATE TAX RETURN .. ESTATE OF PUSKARICH VIRGIL F FILE NO.21 04-0045 ACN 201 DATE 07-12-2005 ESTATE TAX DETERMINATION 1. Credit For State Death Taxes as Verified .00 2. Pennsylvania Inheritance Tax Assessed (Excluding Discount and/or Interest) .00 3. Inheritance Tax Assessed by Other States or Territories of the United States (Excluding Discount and/or Interest) .00 4. Total Inheritance Tax Assessed .00 5. Pennsylvania Estate Tax Due .00 TAX CREDITS: PAYMENT RECEIPT DISCOUNT (+) AMOUNT PAID DATE NUMBER INTEREST/PEN PAID (-) TOTAL TAX CREDIT .00 BALANCE OF TAX DUE .00 INTEREST AND PEN. .00 TOTAL DUE .00 -IF PAID AFTER THIS DATE, SEE REVERSE SIDE IIF TOTAL DUE IS LESS THAN $1, NO PAYMENT IS REQUIRED FOR CALCULATION OF ADDITIONAL INTEREST. IF TOTAL DUE IS REFLECTED AS A "CREDIr' ICRl, YOU HAY BE OUE A REFUND. SEE REVERSE SIDE OF THIS FORH FOR INSTRUCTIONS.) ",,:>'L Q-. COMMONWEALTH OF PENNSYLVANIA r'r\r (leC!('1: fiC DEPARTMENT OF REVENUE Rr:Cnr,'rD ' ;1 , iv[ 1,1[ BUREAU OF INDIVIDUAL TA~~';:I'~"--'-::'-)'~ -:: NOTICE OF DETERMINATION AND INHERITANCE TAX DIVISION ",i'"1 .....1 .' ASSESSMENT OF PENNSYLVANIA PO BOX Z80601 . ... . ESTATE TAX BASED ON FEDERAL HARRISBURG PA 171Z8-060l CLOSING LETTER ZOG5 NO\' 10 M'lI\J: 05 DATE ESTATE OF DATE OF DEATH FILE NUMBER COUNTY ACN '* REV-75' EX IFP 10'-05) {....j! 11-07-2005 PUSKARICH 01-04-2004 21 04-0045 CUMBERLAND 202 APPEAL DATE: 01-06-2006 (See reverse side under Objections) Amount Remitted I I MAKE CHECK PAYABLE AND REMIT PAYMENT VIRGIL F SAMUEL J GONeZ ESQ BUCHANAN INGERSOLL 301 GRANT ST 20TH FL PGH PA 15219 TO: REGISTER OF WILLS CUMBERLAND CO COURT HOUSE CARLISLE, PA 17013 NOTE: To insure proper credit to your account, submit the upper portion of this form with your tax payment. CUT ALONG THIS LINE -+ RETAIN LOWER PORTION FOR YOUR FILES +- RE-V=736--Ex-1rFP--Coi:-02i-----.ji-No-ficE--OF--DETE-RHiN1rfioii-AN-D-AS-SEssiiENT----------------------------- OF PENNSYLVANIA ESTATE TAX BASED ON FEDERAL CLOSING LETTER .. ESTATE OF PUSKARICH VIRGIL F FILE NO.2l 04-0045 ACN 202 DATE 11-07-2005 ESTATE TAX DETERMINATION 1. Credit For State Death Taxes as Verified .00 2. Pennsylvania Inheritance Tax Assessed (Excluding Discount and/or Interest) .00 3. Inheritance Tax Assessed by Other States or Territories of the United States (Excluding Discount and/or Interest) .00 4. Total Inheritance Tax Assessed .00 5. Pennsylvania Estate Tax Due .00 6. Amount of Pennsylvania Estate Tax Previously Assessed Based on Federal Estate Tax Return .00 7. Additional Pennsylvania Estate Tax Due .00 TAX CREDITS: PAYMENT RECEIPT DISCOUNT (+) AMOUNT PAID DATE NUMBER INTEREST/PEN PAID (-) TOTAL TAX CREDIT .00 BALANCE OF TAX DUE .00 INTEREST AND PEN. .00 TOTAL DUE .00 -IF PAID AFTER THIS DATE, SEE REVERSE SIDE (IF TOTAL DUE IS LESS THAN $1, NO PAY"ENT IS"REQUIRED IIi FOR CALCULATION OF ADDITIONAL INTEREST. IF TOTAL DUE IS REFLECTED AS A "CREDIT" (CR), YOU "AY BE uti'- DUE A REFUND. SEE REVERSE SIDE OF THIS FOR" FOR INSTRUCTIONS.) Cumberland County - Register Of wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 12/16/2005 PUSKARICH MARILYN 2496 COPE DRIVE MECHANICSBURG, PA 17055 RE: Estate of PUSKARICH VIRGIL F File Number: 2004-00045 Dear Sir/Madam: It has come to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO.1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 1/04/2006 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, ~ l~AJ~ GLENDA FARNER STRASBAUGH REGISTER OF WILLS cc: File Counsel Judge tJt;, Buchanan Ingersoll PC ATTORNEYS Samuel J. Goncz 4 I 2-562- 1381 gonczsj@bipc.com One Oxford Centre 301 Grant Street 20th Floor Pittsburgh, PA 15219-1410 T 412 562 8800 F 412 562 1041 www.buchananingersoll.com December 27, 2005 Glenda Farner Strasbaugh Register of Wills of Cumberland County One Courthouse Square Carlisle, P A 17013 Re: Estate of Virgil F. Puskarich 2004 - 00045 Dear Madam Register: Enclosed are an original and one copy ofthe Status Report for the above-referenced Estate. Please file the original and return a filed stamped copy to me in the envelope provided. Thank you for your assistance. Please contact me if you have any questions. Sincerely, - .' /-7 .~;1. ,.-::..~ ....... R.Y'<' .. ""-~/ )'/'-.... . .-"- \..._---,. /,/ . . ,,' " r'" j L/ Samuel J. Goncz Enclosures cc: Marilyn Puskarich S. Howard Kline '---~ ) ,.- ) -;-',', ..../:' \f.:.' #1883769-vl Pennsylvania .. New York .. Washington, DC .. Florida .. New Jersey .. Delaware .. Ohio .. California REGISTER OF WILLS OF CUMBERLAND COUNTY ST A TUS REPORT UNDER RULE 6.12 Name of Decedent: Virgil F. Puskarich Date of Death: January 4,2004 No. 2004 - 00045 Pursuant to Rule 6.12 of the Supreme Court Orphans' Court Rules, I report the following with respect to the completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: Yes X No 2. If the answer in No.1 is No, state when the personal representative reasonably believes that the administration will be complete: 3. If the answer to No.1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes No X b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes No d. Copies of receipts, releases, joinders and approvals of formal or informal accounts may be filed with the Clerk of the Orphans' Court and may be attached to this n:port. t~_- - '. '-... .c''''7~-.1.__'--.\ Signature / 1/ / Samuel J. Goncz, Esquire L-/ Buchanan Ingersoll Professional Corporation One Oxford Centre - 20th Floor 301 Grant Street Pittsburgh, PA 15219-1410 (412) 562-1381 Date: ~ember 27,2005 Counsel for Personal Representatives Capacity: Personal Representative X Counsel for Personal Representative # 1883 765-v I ~0 Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 12/06/2005 GONCZ SAMUEL J, ESQUIRE ONE OXFORD CENTRE 301 GRANT STREET 20TH FLOOR PITTSBURGH, PA 15219-1410 RE: Estate of PUSKARICH VIRGIL F File Number: 2004-00045 Dear Sir/Madam: It has come to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July I, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 1/04/2006 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, ~ff..~#~ .~...-,. If. ~~ttw,!;Ol"-!'# 1/'.. . ~\,~.. \....;: f~.l(,.~ v~"{.i.;"'~:.:,.;;r . GLENDA FARNER STRASBAUGH REGISTER OF WILLS cc: File Personal Representative(s) Judge ~t