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IN THE COlJRT OF COMMON PLEAS OF CUMBERLAND COlJNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
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INRE:
THE ESTATE of HERBERT L. HULL,
Deceased
No. 2002 - 00515
Late of Camp Hill Borough
FAMILY SETTLEMENT AGREEMENT
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THIS AGREEMENT, made the <?~day of June, 2005, by, between and among
LAWRENCE C. HULL ("LCH"), MARCIA M. HULL ("MMH") and TRACY A. HULL
("T AH") as the residuary beneficiaries (collectively the "Heirs") of the Last Will of Herbert L.
Hull, deceased (the "Decedent"), and LAWRENCE C. HULL, as Personal Representative of the
Estate of Herbert L. Hull (the "Executor"),
WITNESSETH:
WHEREAS, the undersigned Heirs, being all of the residuary beneficiaries of the Estate of
Herbert L. Hull (the "Estate"), desire by this Agreement to make an end of disputes and to settle
finally all litigation involving the Estate, to release the Executor, and to bring all matters relating
to the administration of the Estate to a close;
NOW THERFORE, the Heirs, the Executor and the Estate, intending to be legally bound, and
in consideration oftheir mutual covenants and assurances, hereby agree as follows:
l. This Agreement shall be filed with the Register of Wills of Cumberland County,
Pennsylvania, and shall have the same force and effect as if a final accounting of the Estate of
Herbert L. Hull had been filed with and confirmed by the Orphans' Court Division of the
Cumberland County Court of Common Pleas (the "Court");
2. Each of the Heirs has been fully advised of his or her rights pertaining to the filing of an
Account and all of them do hereby waive any and all rights which they might have under law to
require that an accounting of the Executor's administration of the Estate be filed with and
approved by the Court;
3. Immediately upon the execution of this Agreement, the Estate and the Executor agree to
the following:
(i) to pay $6,000 to the law firm of Saidis, Shuff, Flower & Lindsay.
(ii) to distribute from Estate principal the sum of $10 1,000. to T AH
to be held in escrow by Scott M. Dinner, Esquire, and released
upon satisfaction of all obligations required under Paragraph 4.
(iii) to convey to T AH the parcels of real property owned by the
Estate and located at 3085 and 3095 Sandalwood Lane, Titusville,
Brevard County, Florida, respectively, [Lots 4 and 5 - Hickory
Forest) with the covenant that nothing has been done or will be
done to encumber T AH' s right, title and interest in the properties
to be conveyed. The failure to perform in good faith the actions
promised shall subject them to pay the reasonable attorneys fees
and related costs, if any, to enforce this provision.
(iv) to pay all other obligations and expenses ofthe Estate.
(v) to distribute the then remaining Estate principal between MMH
and LCH in accordance with the terms of Decedent's last will or
as they otherwise agree.
4. TAH agrees that the Agreement of Sale dated September 16,2001, by and between TAH
and the Decedent is void; that the August 27, 200 I document in which Decedent acknowledged a
debt of $48,000. owing to T AH is void; that T AH will relinquish his interest in two of the three
cemetery lots held by Decedent and the Heirs at Rolling Green Cemetery in Camp Hill,
Pennsylvania; that he consents to the withdrawal of the First and Second Interim Accounts filed
by the Executor (the "Accounts"), and that he will withdraw [with prejudice]: (i) all of his
objections to the Accounts and (ii) his Petition for Rule to Show Cause (the "Petition").
5. The parties agree to execute such other documents as may be necessary or desirable to
facilitate the purposes of this Agreement.
6. The Heirs, hereby fully release and discharge the Executor, and each of the Executor's
agents, attorneys, advisors and counselors, and their respective heirs, legal representatives,
successors and assigns, of and from any and all claims of any nature whatsoever, known or
unknown, which the Heirs now have or hereafter have against the said Executor and his agents
and attorneys, arising out of: (i) the administration of the Estate, (ii) all matters alleged in the
Petition and (iii) the failure of the Executor to file an accounting of such administration with, and
obtain the approval of, the Court.
7. Each of the Heirs hereby consents to the Court's exercising personal jurisdiction over
them in any suit or action arising out of the enforcement of this Agreement.
8. This Agreement may be executed in multiple counterparts, and, when so executed, shall
be binding upon all the parties and their respective heirs, next-of-kin, personal representatives
and assigns.
IN WITNESS WHEREOF, we have subscribed hereunto the day and year first above
appeanng.
WITNESS:
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EXELc~L)
Lawrence C. Hull, as
Personal Representative of the
Estate of Herbert L. Hull, deceased
LIMITED POWER OF ATI'ORNEY
I, Tracy A Hull, of Titusville, Florida ("principal"), hereby appoint Thomas E.
Flower, Esquire, of Carlisle, Pennsylvania my agent. My agent shall have fuU power of
substitution, for me and in my name, to exercise the foUowing power:
1. Execution of Settlement >>Muments. To execute on my behalf any
documents required to be signed by me in order to settle the litigation concerning the
administration and distribution of my father's estate.
IN WITNESS WHEREOF, I have hereunto set my hand and seal on this, the
b to day of June, 2005.
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TRACY!A HULL, Principal
(SEAL)
STATE OF FLORIDA
ss.
COUNTY OF
On this, the t &.. day of June, 2005, before me, a notary public, the undersigned
officer, personally appeared TRACY A HULL., known to me (or satisfuctoriIy proven) to
be the person whose name is subscribed to the within Power of Attorney, and acknowledged
that he executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have
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