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HomeMy WebLinkAbout06-08-11 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FOR CLAIMANT Robert G. Frey by Mr. Yahn by Mr. Faller Linda Stull Harvey Shapiro by Mr. Yahn by Mr. Faller INDEX TO WITNESS DIRECT CROSS REDIRECT RECROSS 9 31 20 -- 30 -_ 35 -- -- __ 41 70 57 76, 80I 69 78 2 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX TO EXHIBITS FOR CLAIMANT IDENTIFIED ADMITTED Ex. No. 1 - list of property lg gl FOR DEFENDANT Ex. No. 1 - letter dated 10-23-08 Ex. No. 2 - dictation dated 9-12-07 Ex. No. 3 - writ dated 4-10-09 IDENTIFIED ADMITTED 21 gl 62 gl 65 gI 3 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Monday, November 9, 2009 Carlisle, Pennsylvania (The following proceedings were held at 9:07 a.m.:) THE COURT: Okay. Why don't we have everybody identify themselves so the court reporter knows who is here and who you represent. You can start, sir. NIIZ. BOSWELL: I'm Jeff Boswell, and I represent Harvey Shapiro who is the Claimant. THE COURT: Okay. MR. YARN: Good morning, Your Honor. Neil Yahn, Y-A-H-N. We represent Alice Phillips. MR. FALLER: George Faller, Jr., representing the Executor, Rob Frey. THE COURT: Okay. All right. You represent the Claimant -- MR. BOSWELL: Yes. THE COURT: -- in this matter. Are there any other claims or claimants that are going to be testifya_ng today? MR. YARN: Your Honor, may I? THE COURT: Yes. MR. YARN: Procedurally, we didn't know whether the Court today was going to address solely the issue surrounding the claim by Dr. Shapiro against the Estate and then as to whether we were then going to address 4 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what I will call the outstanding tangible personal. marital property issues that continue on with regards to the Estate. It was our understanding that we were focussing initially on Dr. Shapiro and his claim. And then in the interest of time -- THE COURT: All right. Let's do that first, and then we'll see what time we have left. Proceed. Do you want to make an opening statement at all? Or you feel comfortable just having your client come up and start to testify? Ngt. BOSWELL: Well, my client will testify and then with the Executor as well. But essentially, the claim regards personal property that was on the real property of the Estate, the personal property owned by Harvey Shapiro who was resident on the Estate. And it's our contention that the Executor knew of that personal property; and then when Dr. Shapiro made arrangements to go get that property, the property was gone. And essentially, Harvey Shapiro had contact with the Executor, provided a list, etc., and some property was recovered. But by far and away, most of the property is still missing. THE COURT: Okay. Do you want to say something, sir? MR. YARN: Your Honor, if I could, please. 5 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Neil Yahn on behalf of Alice Phillips. One of the critical points to note for this matter is Dr. Shapiro was an expert who was engaged through Shienvold office, Shienvold and Associates, a psychologist out of Harrisburg. Dr. Shapiro was an employee of Dr. Shienvold's office. Through his office, Dr. Shapiro was engaged to perform not only a psychiatric assessment on Miss Phillips but also to provide for her care. It was part of that care that began in or about August of 2006. We'll provide this via the evidence today. Dr. Shapiro at one point through the course of his care engaged in then a relationship with Miss Phillips. The context of that relationship are now a matter currently before the Dauphin County Court. There is a writ of summons that has been filed. There is also a certificate of merit to that writ. I understand the complaint has not been filed today; but it would be our position, Your Honor, Dr. Shapiro ultimately provided an analysis of Miss Phillips that included but not limited to depression, anxiety, the IQ of that an individual at or about fourth or fifth grade. It would be our position, Your Honor, that any matters surrounding the tangible personal property of Dr. Shapiro should be addressed in that matter. There is currently a writ filed. If he would like to file a 6 2 3 4 5 6 7 8 9 10 11 12 13 I4 15 16 17 18 19 20 21 22 23 24 25 counterclaim or any third party cross claim, he should file that in that matter. And, Your Honor, this is an inappropriate forum for Dr. Shapiro to be making his claim against the Estate given he was the physician caring fcr Miss Phillips. He is now arguing that he would like his property returned when the nexus to that tangible personal property that's allegedly missing that he placed in the hands of a fourth grade individual that he diagno:~ed, he's now coming before this Court and saying, I'd like my property back, when the appropriate jurisdiction for that matter, Your Honor, is Dauphin County. THE COURT: What type of that action is that. in Dauphin County again? Ngt. YARN: Your Honor, that is a medical malpractice claim under negligence. THE COURT: Okay. NIlZ. FALLER: Yes, sir. And if we might, Your Honor, I think this is a claim against the Executor of the Estate. The Estate did own the real property as you well know. But the Estate was not in possession of the real property when Mr. Shapiro put the property there. So we feel we're just kind of here as a bystander because we never had possession of this tangible personal property. As far as we're concerned, the personal 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 property left when we got possession of the real property back. THE COURT: Okay. So there was no personal property of the Doctor's at the real Estate when you regained possession. Is that what you're saying? MR. FALLER: That's correct. And we went through with Mr. Yawn. We went through -- well, right before, didn't we? NR2. YARN: Your Honor, I believe -- we did go through the house itself. It was an understanding at least pursuant to the order that we were going to have the opportunity to go back through. But that relates to tangible personal property between Miss Phillips and L.L., not with regards to Dr. Shapiro. MR. FALLER: Correct. Sorry. There is one treadmill and some clothing that was on the list; and we're, you know, ready to turn it over. THE COURT: Okay. Anything else initially? Do you want to respond to his statement that the -- this Court should not hear this claim? MR. BOSWELL: This claim does -- just with regard to the tangible personal property, there is nothing in this claim with regard to care. The professional care relationship with Dr. Shapiro ended sometime before this property claim arose. I don't have knowledge with regard to 8 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the claim in Dauphin County. THE COURT: You don't? MR. BOSWELL: I don't believe that the professional claims alleged with regard to that action in Dauphin County has anything to do with the personal property. THE COURT: All right. I'll allow you to proceed. Go ahead. MR. BOSWELL: I'd like to call Robert Frey, please. THE COURT: Okay. Mr. Frey. Where do you want him to sit? ROBERT G. FREY, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. BOSWELL: Q Mr. Frey, would you please identify yourself? A My name is Robert G. Frey. My office address is 5 South Hanover Street, Carlisle. Q And you're the executor of the Phillips' Estate? A I am, yes . Q As executor of the Phillips' Estate, you're aware of the real property? 9 2 3 4 5 6 7 8 9 10 11 12 ,3 L 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q And when did it come to your attention that Harvey Phillips was residing -- A Harvey Shapiro? Q I'm sorry. Excuse me. Harvey Shapiro. A I received a -- I guess it would have been late October of 2008; and I received a telephone call_ from Dr. Shapiro. Our hearing with Judge Rehkamp, I believe, was October 21st. I have to check my calendar, and ttlis would have been sometime after that but before when we went through the house on October 28th I think. Q During the month of October, did you go through the house two times with Linda Stull? A We went through one time before Alice Phillips had vacated the property; and that would have been around the, I think, October 28th time frame, somewhere -- I'm not exactly sure on that date and then subsequently went through one time with Dr. Shapiro. It was a Saturday maybe a week or so later I believe. Maybe it was longer. Q Now when you went through with Dr. Shapiro then later, did you notice that personal property that had been there previous inspection of the house or walked through the house and was not there? A Yes. There was a large amount of property that had been moved when. -- when Alice moved from the house. i0 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q When you went through the property with Linda Stull previously, did -- in mid October, did -- you were aware that on the -- in the house there was property of the Estate, correct? A Yes. Q And property of Alice Phillips as well? A Yes. Yes, I believe so. Q You were aware there was also property of. Harvey Shapiro? A There appeared to be in that the only item that I could speak of specifically was a dismantled pool table which I knew was not the Estate's property. Dr. Shapiro had mentioned that he had one there. I do not know whose property it was, but that was my impression. NHt. YARN: Your Honor, may I object? He's continuing down a line of questions that the Executor does not have actual knowledge as to who the ownership of certain property as to whether between Miss Phillips or Dr. Shapiro. As a result, the better party to provide testimony to that would be Dr. Shapiro himself as to the specific items. THE COURT: Okay. I understand. Where are you going with this? MR. BOSWELL: Well, Dr. Shapiro will testify as to those items; but I'm -- with these questions, I'm trying to establish that the Executor knew there was other 11 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 property on the -- on the Estate property -- on the Estate real property. THE COURT: All right. BY NHt . BOSWELL Q And you were aware of the -- the Estate's personal property? A Well, there's a lot of property, yes. In the general sense, I was aware of it, yes. I had not been in the house very often since Mr. Phillips died, I think on two other occasions. So as far as having an intimate knowledge of all of the furnishings and things of that nature, no; but I was generally familiar with it. Q As Executor, you had obtained appraisals of the personal property, correct? A Yes. Q So -- and you had reviewed those personal_ properties when you filed the tax returns; is that correct? A I certainly did, yes. Q Did you have a dispute with regard to Alice Phillips with regard to any of the personal property cf the Estate? A Yes. Yes. Q Does that dispute still exist today with regard to some items? A We still believe there was property that 12 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 should not have been removed and was. That's our position, yes. Q And in -- when did you establish that. position that -- was it before this October hearing you referred to, October 2008 hearing? A No. It would have been after the October hearing. And -- well, it was my understanding or thought that procedure was set at that hearing that we would meet at the property and decide what was to be taken out and what was to remain. But by the time we were able, allowed to get into the house, a lot of things had already been moved or were boxed up ready to be moved. Q You're aware that Dr. Shapiro was residing at the house for some time? A I was not aware until he told me in October of 2008. Q And was that -- when he told you that, did he tell you that before you and Dr. Shapiro went to the property? A Yes. Q And was that -- was that before or after your -- your walkthrough with Linda Stull? A It was before the walkthrough. Q What was the purpose of your walkthrough with Linda Stull before the hearing? 13 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Well, as I said, my thought was the purpose was to get an understanding of what was to -- what was definitely Estate property remained, what was definitely Alice's property that would be allowed to go, and what was still in dispute. But as I said, in the days following that hearing and before we were there, moving had already started to occur. And so what eventually -- essentially was the purpose, I guess, when we got there was to get an idea of what still remained and what would was required to remain and what we needed to try to retrieve. Q When did you then learn that the property -- personal property was removed from the residence? NII2. FALLER: Objection to the extent that we're not talking about any particular piece of property. I mean -- he wasn't in possession of the property. So how would he know what personal property was going in and out? MR. BOSWELL: Your Honor, if I might address that? The witness testified that he was aware that from the walkthrough with Linda Stull that there was a significant property and then soon there was a second walkthrough and much of that personal property had been removed. THE COURT: Right. MR. BOSWELL: My question is -- and maybe I could address the question better at that time period. 14 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY NIlt . BOSWELL Q Is it during the second walkthrough that that was the first time that you were aware that property was removed? A No. I can't give you the exact date but sometime between those -- the -- the hearing in New Bloomfield and our meeting at the property, I received a telephone call. And I'm not sure if it was from Linda Stull or her brother Lynn Phillips, III, that they noticed a -- a van at the property. And I recall at this time we were not really allowed inside the fence as we described it. We were allowed on the exterior property area but not on the curtilage of the residence. And I did drive out and confirm that there was a -- a U-Haul truck backed up to the house at which point I called the attorneys that are representing me in this matter. Mr. Faller wasn't available, so I spoke to his partner No Otto. And it's my understanding that No and Mr. Yahn had some conversations, and I thought at that point that there was agreement there wouldn't be anything more moved. I happened to have a real estate settlement sort of on that direction on west side of Carlisle later in the afternoon. After that settlement, I drove out again, 15 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 saw that the U-Haul had been moved which I thought was a good sign. It was parked away but then noticed there was a second truck backed up to -- to the house. And although I could not stop what was going on, I thought I needed to at least confirm that there were things moving. And I did look in the back of the truck and saw that one the inclinators that had been installed for handicap access tc the second floor had been removed and that was sitting in the back. That's really the only thing I noticed there regarding any other property. So that's basically the extent of my knowledge of things moving. Q At that time as Executor, did you have are agreement that Alice Phillips, with anyone, could remove property? A I thought the -- well, the -- this is my opinion. I thought that there was not going to be moving before we met; but obviously, there are other opinions differently. Q Then perhaps two weeks later -- recognize you don't know the exact time -- you went through the property with Harvey Shapiro? A Yes. Q And did he identify then the pool table that was still there? A No. I don't think the pool table was there 16 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 then. I think it was gone. Q Did he tell you at that time that items of personal property that belonged to him were no longer there? A Yes. Yes, he did. Q Did he at that time identify particular items that you -- you can recall? A He mentioned various things. There were some things that were his that were there; and he gathered them up. And -- but he certainly named other things that had been in a certain spot and were no longer there. Q Did he then eventually send you a list of those items? A Yes. Q And do you recall when he sent you that list? A I'm thinking it may have been that December. Q But some months -- A Still in 2008 I think it was. But several weeks or mont hs later, yes. Q Did he revise the list then at a later time? A I believe so, yes. Q Okay. I'm going to show you a -- may I have this identifi ed? MR. FALLER: For the record, Your Honor, I believe it was also attached to the petition that we are here on today. It's an exhibit to the petition. 17 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. YARN: I'll stipulate it's the same list attached to the petition.. MR. BOSWELL: May I show this, please? THE COURT: Yes. BY MR. BOSWELL: Q Can you identify that list? Now, I note that that says revised list. And you testified that there was a first list, and then it was later revised. Is that -- A This looks to be the list he sent to me, yes. Q Does that list refresh your recollection as to any items you discussed with Harvey Shapiro when ycu walked through the house? A Yes. And again, this is a fairly long list; but I -- I do recall him mentioning paintings and some glassware and a -- I don't see it on here. But I know he mentioned a spoon table, but I don't see that here. I'm sure it's on here somewhere. Q And in your inspections then or walkthroughs of the house, did you ever then -- then find those particular items? A No. Q And mister -- and Dr. Shapiro made a -- sent that list to you, you understood that he had contacted you with regard to the recovery of those items; is that correct? A Yes. 18 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did you then. encourage Dr. Shapiro to make a claim against the Estate? A Well, yes, in that he had asked me what -- what I could do for him and to assist in this matter. And I said, I really -- and he had some other concerns also that I couldn't -- I couldn't do anything in regard to those. But if he felt I had some obligation he should file a claim and that that would at least provide a center for it to be resolved somehow. So to that extent, yes, I did suggest it. He thought he had a claim he should file. Q When -- referring to that list and your recollection of your walkthroughs, are you aware of items that were returned to Harvey Shapiro that had been in the house? A That were returned? Q Yes. A The only ones I'm aware of are what we returned to him that day, we being Linda and I went through the house with him. And we picked up items. Q Are you aware of any items now that -- that are his that are at the house or the property? A There is a -- a treadmill which we -- which we identified at the time but did not move it at that time. Dr. Shapiro was on crutches, so he couldn't be of much assistance. And I didn't -- we drove out in my SUV but 19 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 l8 19 20 21 22 23 24 25 didn't have room for large items. So we just set that aside. Since that time in cleaning up, Linda found clothing not her father's size, men's clothing not her father's size. So she assumes that they may be Dr. Shapiro's. That is all that I'm aware of. Q And did -- as Executor, you would be willing to return those to Dr. Shapiro? A Certainly, yes. Q Are you aware of any time that the police have been contacted with regard to items removed from the Estate? A With regard to items? Q Any items removed from the Estate property? A No, I don't think so. MR. BOSWELL: I have no other questions at this time. THE COURT: Okay. Mr. Yahn. CROSS EXAMINATION BY MR. YARN: Q Good morning, Mr. Frey. I'm Neil Yahn on behalf of the -- of Alice Phillips. Could I just clarify a few things for the record? You referenced a Linda Stull. Just for the record, could you clarify who that party is? A Certainly. I'm sorry. Linda Stull is the 20 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21 2 3 4 5 6 i 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, I believe so. Q And if you could, go down to the very first paragraph. It's directed to you and says, In Re: Illegally held belongings, does it not? A Yes, it does. Q And it's directed to you as the Executor of the Estate of L.B. Phillips, correct? A Yes, it is. Q Is Dr. Shapiro an intestate heir under the Estate of L.B. Phillips? A No. Q Is he beneficiary under the Estate of L.B. Phillips? A No, he is not. Q Within any testamentary document was Dr. Harry Shapiro named? A No. Q It appears to be that Dr. Shaprro then writes this to confirm you as the Executor for the Estate of L.B. Phillips that a great number of my belongings have been wrongly seized from me and are being illegally held 93 Encks Mill Road, Carlisle, the home of the late L.B. Phillips. I would like to just for backdrop clarify who actually was in possession of the property pursuant to a court order at the time of this letter? 22 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Alice Phillips. Q Alice Phillips was, and that was pursuant to an order of this Court that provides that Miss Phillips would stay on the residence and what I will define as the curtilage you referenced earlier, correct? A Yes. Q And what curtilage was that specifically pursuant to that order? A Well -- and there are exhibits filed -- but if you view the property, there is -- it's a farm in large part acreage wise. But in the center of that acreage is finished residential area. It's for the most part setoff by a white fence that surrounds it and the house and a two-unit rental property in that residential area as well as landscaping. Q And that order from this Court stems from litigation surrounding certain testamentary documents and a prenuptial agreement between the decedent, L.B. Phillips, and Miss Phillips, correct? A Yes. Q In fact, that order was merely a stay pending a resolution of that matter between Mr. Phillips and the Estate -- Miss Phillips and the Estate? A I believe that's correct, yes. Q And so in fact, during the period the Estate 23 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 I8 19 20 21 22 23 24 25 actually wasn't in ownership of the property pending the period what I'll call adjudication of the matter before the Court? A That's -- certainly not in possession. That we -- neither I nor any of the heirs crossed over that fence unless it was -- I can recall one instance at your request and then otherwise, in October of 2008. Q Okay. When was the first time that Dr. Shapiro contacted you about his personal property? A Well, from this letter I would have to sa:~ it was before October 23rd if that's a correct date. My recollection it was after -- well, yes, it was after the settlement agreement had been agreed to. And I don't remember that date. And I believe it was after our hearing that confirmed that agreement, but there's a possibility it could have been been before that but not much before that. Q And how did Dr. Shapiro introduce himself to you? A He left a phone message which I did not return because I had concerns. If you may recall, issues of discovery were at one point important in this matter; and I did not want to have communications that might be thought of as crossing the discovery line. But he identified himself. i think the words were the infamous Harvey Shapiro I think was how he introduced r~imself. 24 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And -- to be honest, I didn't recognize the name because I did not know him at that time. But subsequently, there was either another contact which I believe also was a voice mail in which he stated concerns of property being removed from the residence. And at that point, I felt I needed to contact him because that was a concern of mine as Executor. Q And during the course of that conversation -- well, tell me about that conversation and contact. A Well, Dr. Shapiro said that he had been living at the property and that he was no longer there, that the relationship between he and Alice -- I don't want to pu.t any special inference on relationship -- just that they were no longer on friendly terms, that it was an adversarial one at that point. And he -- ask further. I don't know what else you want to know. Q If you could, I'm going to direct you back t.o the letter for a moment. A Certainly. Q And it provides this list, and you'll see it begins on important this list is very incomplete from Ray K's house. Do you know who Ray K is? A I do not know personally, only what Dr. Shapiro told me. Q And what did he tell you? 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Well, he told me that I believe that he was a friend of Alice's I think in the landscaping business and had some -- they had somehow become acquainted and that Dr. Shapiro knew him from his time when they -- when he resided there at the property. Q Okay. And then it further states from the office area. Do you know what he's referencing there? I'm on the first page of -- A Yes. Thank you. Yes. A part of the house but set off on the -- if you're looking at the front door on the right-hand side was an office that also had a separate entrance and was used when Mr. Phillips was alive for managing the rental properties. And he had an employee that had her desk and computer there. Q Okay. And earlier you referenced that Dr. Shapiro actually came over and did remove some items; is that correct? A Yes. Q Do you recall specifically any of these items on this list that he removed? And please take your time to examine the document. A Well, third item on the page 2 books in LB's office. I know he did pick up a few books that he found one or two, but I don't think there was any large number. I can't really tell you I see anything else that jogged a 26 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 memory for me. Q At that point, do you recall if Dr. Shapiro created a list of the items he removed that day? A I believe that's what he did, yes. Q He did create a list? I'll restate the question. The day that Dr. Shapiro removed items from the house, did he create a list of the items he removed? A Not while we were there, no. I received the list later. And my recollection is this is -- your Exhibit 1, Respondent Exhibit 1 is that list. MR. FALLER: He misunderstands. He is asking did he make a list of what he took with him. THE WITNESS: I'm sorry. A list of what he took, no. No. I did not see a list of what was taken. BY MR. YARN: Q Okay. Nor aia ne proviae you wiLii clue: A No. Q Thank you. Okay. I'm going to direct your attention to the second page. And it says on page 2 Phillipsl2l and references from Miss Lucy's murder room. A Yes. Q Could you please describe for us what Miss Lucy's murder room is if you have any knowledge? A Well, my -- my understanding from -- from speaking with Dr. Shapiro is that one cf the things that he 27 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was told while he was living there was that the decedent. had his first wife killed medically somehow. His first wife was named Lucy, and she had been ill for a considerable period of time. And because of her illness, a room had sort of been set up for her on the first floor behind the kitchen area. And that I believe probably is where she eventually did pass away, and I think that's the room he's referring to. Q Okay. Do you have any other foundation of the belief of that sentence? A No. Q And what is your understanding? Where did you come about to hear that information by way of the Miss Lucy murd er room? A From Dr. Shapiro. Q And Dr. Shapiro communicated that to you in the context of your initial conversation? A Yes. Q And what -- what if anything did he tell you or where did h e tell you he learned that information from? A He told me he learned it from -- from Alice. Q From Miss Phillips? A Yes. Q Were you aware of the patient/client 28 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 relationship bind between Dr. Shapiro and Miss Phillips? A Yes. Q And did he advise you that he was perhaps -- strike that. What else, if anything, did Dr. Shapiro communicate to you with regard to Miss Phillips' confidential communications to him? A Weil, there was probably a number of things made which I don't remember anymore. One that for personal reasons I do remember is that he said that Miss Phillips said that the decedent had my sister murdered. My sister died when she was 14; and -- and I think Dr. Shapiro believed that. And I remember discussing with him I was pretty sure that wasn't the case because I had read her autopsy and she died of cancer. But there are -- there are a number of other statements of murders and criminal activity I think by the decedent during his lifetime. Q By the decedent that Dr. Shapiro was communicating to you that he learned from Miss Phillips? A Yes. Q Are you ware of a certain cause of action currently against Dr. Shapiro in the Dauphin County Court of Common Pleas? A Not before your statements this morning. Q If you could turn to the third page date 29 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 stamped Phillipsl22? If you could, there's a reference to a trailer licensed to me and it says from the driveway? A Yes. Q Is there a trailer there today? A No. Q I just want to confirm again that Dr. Shapiro is not a intestate or testate heir under the Estate of L.B. Phillips, correct? A That is certainly my understanding, yes. NIlZ. YARN: We have nothing further, Your Honor? THE COURT: Do you have any questions for your client? MR. FALLER: Just briefly. CROSS EXAMINATION BY MR. FALLER: Q Mr. Frey, when you did learn and got that letter, did -- was that communicated to Mr. Yahn whose client was in possession of the property at that time? A Yes, it was. I don't think it was immediate, and I don't remember what the time frame was. But= I think it was part of the communications we did have concerning personal property that I felt was -- was Estate property. I think was included in that. 30 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FALLER: I don't have anything else. THE COURT: Any redirect? NHt. BOSWELL: Yes, briefly, Your Honor. REDIRECT EXAMINATION BY MR. BOSWELL: Q With regard to the mentioned trailer, are -- are you aware of, well, that Harvey Shapiro did claim there was a trailer there on the property? A Yes. Q And do you have a recollection of ever seeing that trailer there? A No, I don't. Although it's -- as I said, I did not go into the -- the residential area; and it's fairly well treed along that fence line. So it's not easy to see, and there are buildings that could have concealed it. But no, I do not recall seeing it. Q As I recall your testimony, there is no trailer there today? A That is correct. Q In the conversations that you had testified as to the contact made by Harvey Shapiro, the first contact made, do you recall the date when that contact was made? A No, only that I can somewhat place the date because of what I recall of the message in that I believe 31 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 there was some reference to his knowledge of a settlement agreement. So it would have been after that settlement agreement was reached. What I'm not clear of is whether it was before or after -- I think I initially testified I thought it was after the October hearing in New Bloomfield. Certainly my first communication would have been after that time. There may have been a message before that time; and the reason I'm thinking about this is as said before, I had concerns about talking with anyone that might overstep discovery issues and I certainly would not have had any communication with him before we had that hearing where Judge Rehkamp had confirmed the order of settlement. But it is possible he could have called me before then. I'm not sure, but it be would have been somewhere in that October 2008 time frame. Q But you did go through the property with Linda Stull prior to that hearing? A No. No. I went through that a week to two weeks after that hearing. Q And at that hearing, did items of personal property and -- claimed by Alice Phillips and that was claimed by the Estate be subject or part of that hearing? A We didn't -- it's my recollection we dial not 32 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 get into any details on that other than that jurisdiction would be retained to resolve any issues regarding personal property. Q But it is your recollection that at the hearing that there was a dispute with regard to personal property items? A Well, I think there was at least a concern on my part and on the part of the children that as part cf the moving from the residence there could be issues of what should be allowed to go and what should not be allowed to go. Q And is it that concern that prompted your walkthrough with Linda Stull who is one of the children as -- as to a concern or claim that she may have with regard to items that should be retained by the Estate? A Yes. Yes. Q And thereafter when you had the second walkthrough, was Harvey Shapiro with you at that time and Linda Stull? A Yes. It was -- it was -- the purpose of that walkthrough was really I think mainly as a courtesy for Dr. Shapiro to allow him to see what was there and retrieve what he thought was his that we did not have any dispute regarding. Q And at that hearing, he did express to you 33 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that those items were -- were not there that he had left there? A Yes. He -- he was rather emphatic that there were a lot of things that were missing. Q And then did Linda Stull also tell you that items were missing that had been there before that were Estate items? A Yes. Q And were those Estate items as to which she had asserted claims as one of the children? A Well, not formally. She has not filed any claim. But yes, she has certainly asserted that there are there -- they should be Estate items and not the property of Miss Phillips. Q And these are family items that she had an attachment or sentimental attachment to; is that correct? A A number of them are, yes. Ngt. BOSWELL: No other questions. Thank you. THE COURT: Do you have anything else? MR. YARN: Your Honor, the only thing I ask is that we reserve our rights to ask questions of this witness as it relates to tangible personal property that we're not waiving that right between the Estate. THE COURT: All right. NHt. YARN: Nothing further. 34 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: You may step down, sir. Next witness. MR. BOSWELL: Like to call Linda Stull briefly. THE COURT: Okay. LINDA STULL, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. BOSWELL: Q Good morning, Miss Stull. Am I saying your name correctly? A Yes. Q Okay. yourself? Thank you. Would you please identify A My name is Linda Stull, and L.B. Phillips wasl my father. Q And when did you come to learn that -- know Harvey Shapiro. When did you first meet him? A I didn't meet him until like Mr. Frey said after we had been in New Bloomfield and after he -- he had originally talked to Mr. Frey and then had placed a call to me. Q Did you talk to Harvey Shapiro by telephone or any other - - or any person prior. to your walkthrough of 35 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the property in October? A The walkthrough with Harvey? Q No, with your first walkthrough with Mr. Frey? A The first walkthrough we went through with -- all the attorneys went through. That was before Alice left. The second one I was able to go through with all of the attorneys after she left, and it was the third trip through that Mr. Shapiro had asked if he could retrieve any of his personal things. That's when when we went through. Q At the first or second walkthrough, Harvey Shapiro was not present, correct? A No. Q In the first walkthrough, were you aware of any property at the residence or the curtilage as we call it property that belonged to Harvey Shapiro? Q Actually at that point in time when we went. through, it was -- it was so hard on me to see the condition of the property that I wasn't thinking clearly. But I can remember Mr. Frey and one of the other attorneys -- actually, I think it was Mr. Yahn -- saying, well, treat must be the pool table. I did not know -- it was a -- a pool table that had the legs removed. And I remember looking across from that and there were many pictures that were piled up, and they did 36 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not look like pictures my parents would have liked. And I don't believe they would have been pictures that Alice would have understood. They were more of an artsy type, and I just assumed that maybe they could have been Mr. Shapiro's. But I have -- I have no knowledge of that. Q In the second walkthrough, did any of that change? Did you have more knowledge as to what might belong to Mr. Shapiro at that time? A I think the only thing that was there was a dog training book. I think there was a pair of shorts that we saw that he said were his, and I think he took those home. And there was a -- a treadmill. Q This would have been at the walkthrough that you were with Mr. Frey prior -- not the walkthrough when you were with Harvey Shapiro present. You testified there were three walkthroughs? A Three walkthroughs and Mr. Shapiro was the third. Q In the second walkthrough, did you have more knowledge as to items that belonged to Harvey Shapiro? A No, I did not. Q And the second walkthrough, did you also see the -- the pictures or the paintings and items you testified? A No. No. 37 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Was there a difference in the quantity of personal property on the site between the second walkthrough and the third walkthrough when Harvey Shapiro was present? A The second walkthrough would have been after Alice had moved. And I -- I didn't see any difference between that time and the time that Mr. Shapiro came through, no. Q So that time -- was the amount of personal property moved significant? I'm trying to understand. The first time you went through, were there a significant number of personal property items on site? And you're indicating ves? A You mean our property or Mr. Shapiro's? Q Either. Either, both, or -- A The only thing I recollect the first time were pictures, and I don't know if they were his and a pool table. The second time, I didn't see the pictures or the pool table. There were just -- it was just too hard on me to see what I was seeing. Q I understand. A And -- and when we took Mr. Shapiro, the only thing that I think was a dog training book -- I mean, everything else was gore that he said could have been his, believe, other than that and the treadmill. Q And the second walkthrough was after the 38 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 hearing in New Bloomfield? A Yes. Q Okay. And -- A It was after Alice was out; and that was after the -- yes, I think she moved the very same day or next day after the heari_r~g. Q Is it your recollection of that time period that there was a disagreement with regard to personal property items that the Estate claimed and perhaps Alice was claiming? A Yes, there was. Q And is it your recollection when you went through the second time at the hearing that the items that belonged to the Estate were gone? A That's true. Q Do you recall in any of the walkthroughs the existence of a trailer on property? A I had seen the trailer on the property. I was the only one permitted on the outskirts. There was a court order we weren't even allowed on the other property other than myself. And I would take my brother so that I had proof of anything that went on because I managed the townhouses. And we had go to the warehouse for the supplies; and I did -- I could see early on there had been a trailer there. But I don't know whose trailer it was. 39 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you have any recollection the trailer belonged to the Estate? A No. Q So would your answer then be that the trailer -- you don't believe of the trailer belonged to the Estate; is that correct? A I'm sure that we did not have -- all of our trailers are much larger; and they were all locked in the barn. Q Is -- now to your knowledge, does the Estate still have a claim with regard to personal property items that the Estate no longer has? A I would have to ask Rob if there's a -- I know that I'm claiming that there are personal things that would have been my parents that are not there; but I don't think there's anything in writing. There's no claim in writing. Q You would agree with the Executor you've communicated your concern with regard to personal property items that belonged to your parents -- A Right. Q -- that are no longer present? A Yes. MR. BOSWELL: Thank you. MR. YARN: TrJe have nothing for this witness, 40 2 3 4 5 6 7 8 9 10 11 1 ?_ 13 14 15 16 17 18 19 20 21 22 23 24 25 Your Honor, provided we're reserving our right. THE COURT: Okay. Very good. NHt. FALLER: Nothing, Your Honor. THE COURT: You may step down, ma'am. Okay. NIlZ. BOSWELL: Call Harvey Shapiro. HARVEY SHAPIRO, having been duly sworn, testified as follows: DIRECT EXAMINATION BY NH2 . BOSWELL Q Would you please identify who you are? A Harvey Shapiro. I reside at 8 Oak Lane Drive, Carlisle, Pennsylvania. Q At one time, did you reside at 93 Encks Mill Road, Carlisle? A Yes. Q And to your knowledge, who owned that property? A The Estate of L.B. Phillips. Q Did you at -- when you moved to the property, did you take any personal property that belonged to you there to that property? A Yes, quite a bit. Q You're aware of two lists that have been reviewed by Mr. Frey, correct? 41 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q The list that was identified as Respondent's No. 1 dated October 23, 2008, did you fashion that letter and the list? A Yes, I did. Q When did you do that? A I would have done that at the time that -- the date on the list. Q Did you send that to Mr. Frey at that time? A Yes, I did by mail. Q And was that mail returned to you? A No. Q Was that list then later faxed to Mr. Frey? A I believe -- I believe it was. I don't recall precisely. Q Do you recall why it was later faxed? A No, I don't recall that. I don't recall, but I would have mailed. It was very important to me obviously. Q Why was it important for you to mail it at that time? A I wanted him to have an original copy with my original signature of the letter which was composed by a nonlawyer. Q At that -- at that time -- and you identified that as October 23? 42 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I'm not sure it was mailed that day. That's when it was composed. It may have been mailed -- Q Is there any particular reason or anything that you recollect about that date or time period as to why it was important to mail him a letter at that time as opposed to a month later or two months later? A Yes. I spoke with Mr. Frey. My recollection of the time is a bit different from his. It would have been in early October, early October to mid at the latest. This was after -- and it hasn't come up in the hearing yet -- an attempt I made to recover my property with Mrs. Phillips' permission. But I was not allowed to recover very much of it. I can explain that to the Court. That was on 9-27 realizing that my property would not be returned to me or at least believing so, I contacted Mr. Frey I believe i.n the first 10 days or 15 of October. At that time, he recommended to me that I file against the Estate, which was a rather direct recommendation. I did ask him what if anything he could do to help me thinking he could do nothing, and it never occurred to me to file against the Estate. I had never heard of such a thing. I'm not an attorney. But he directly I might almost say strongly recommended that. At that time, as now I suppose but much 43 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 more then, conflicts were going on and I was able to provide him with information that could be useful I felt. And that's why I call him to help him. But in the end -- Q Now you had testified -- you had just mentioned with regard to conflicts. What conflicts and at what time? This was in early October; is that correct, early October 2008? A Yes. There were extensive -- there had been extensive conflicts over the prenuptial agreement; and they had extended over several years as I'm sure ,the Colzrt i.s aware. There was a -- Mr. Frey had -- there was property in the house that was not marital property that I believed Miss Phillips was going to remove. I realize this is not about her or who removed what, but I felt I could be of assistanr_e with reference to that property especially -- Q Were you believing at that time that was Estate property? A Yes, I did believe that, many, many boxes as it turned out of valuable glassware, collector glass. Q And was that collection of glassware eventually given to the Estate or placed in the possession of the Estate through Mr. Frey? A I'm sorry. Placed in possession of the Estate by Mr. Frey? I didn't quite understand that. Q Or to Mr. Frey, Mr_. Frey being the Estate? 44 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A When I was last at the Estate -- Q When was that? A -- the third walkthrough that Mrs. Stull and Mr. Frey have referred to, there were in the garage many boxes sealed, apparently neatly packed boxes; and there had. to be 15, probably 20, stacked 3 deep along the wall. Mr. Frey told me that that was the glassware which previously had been in display cabinets througho~.~t the house and on -- I may not be using the term correctly -- valances above windows. All throughout the house was this so-called amethyst glass that is valuable collector w~iich Mr. Phillips and his first wife had collected. Q Is it your understanding that -- A My understanding at that time was treat it had been removed in those boxes and subsequently returned. That's what Mr. Frey told me. Q And with your conversation witr~ Mr. Frey, is it your understanding that Mr. Frey was trying to obtain possession of that collection? A Very much so and other times. Q As Estate property? A Absolutely. Yes, sir. MR. YARN: Your Honor, I would like to object. We are here on behalf's the Claimant's claim with regard to his property. He's providing testimony with 45 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 regards to a matter that's currently not, as I understand it, before this Court. THE COURT: That's right. Let's get to his claim, please. BY Ngt . BOSWELL Q And the boxes in the garage were not your property, correct? A Correct. Q When did you -- when you contacted Mr. Frey then, had you removed -- had you moved from 19 Encks Mill Road? A Yes, as of September 8 -- well, September 9th. Q So in your discussion with Mr. Frey with regard to the Estate property, did you also tell him that you wanted to recover your property? A Yes. Yes. I would have mentioned that of course. I wanted to. I didn't see how, but I wanted to of course. Q And in those conversations with him at that time, you learned that the Estate had dispute with regard to personal property also; is that correct? A Yes. I may have known it -- forgive me for pausing. I'm trying to recall. There were a number of items that Mrs. Phillips claimed they could legally take and 46 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 she had -- again, it's not about her. But she had told me that they were in contest, that the Estate might not agree with her but as far as she was concerned she would take them. Q I'm not asking you questions with regard to those items. In your conversation with Mr. Frey, you knew there was a dispute over disagreements with regard to personal property? A Yes. Yes. Q Are you aware that Mr. Frey then went through the property with Linda Stull before your walkthrough the property in November? A Yes, I am, for it was Mr. Frey who called me after the second walkthrough and said, I have some bad news for you. Q What did he tell you? A And the news was your thing -- your possessions are not here anymore. He might have said some of them -- some of them might be here but the bulk of what you claim is yours is no longer here. Q And this is -- this is before your walkthrough with him, correct? A Yes, my walkthrough with him was to see if anything of mine remained. Q So it's your belief that he was in possession 47 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of this letter, the first letter was Respondents No. 1 prior to that second walkthrough; is that correct? A Absolutely because I wrote my broke my foot I believe, on November 2nd, certainly early November. And I was, as he said, on crutches at the time of that walkthrough. Q Thereafter in November when you went through the property with Mr. Frey, you were on crutches? A Yes. Q And did you confirm that the items that you had listed in the Respondent's No. 1 which was the October 23 letter were not there? A Yes. The October 23 letter was composed based on that walk -- that -- what was there. Let me see if I can remember. The October 23 letter was composed -- NHt. BOSWELL: Your Honor, may I show him the letter? THE COURT: Yes. THE WITNESS: That's not quite right. Let me correct that. It was -- it was composed based on what -- let me explain this. On September 27th with permission of Mrs. Phillips and in an arrangement also confirmed or supported by Mr. Yahn and my then attorney, a rainy Saturday I rented a U-Haul truck and had two gentlemen to help me because Mrs. Phillips and mister -- as I understood it 48 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 through my attorney then, Mr. Yahn and my then attorney had agreed that I could pick up all my belongings. I rented a large U-Haul truck and went there. To my surprise or at least I was un -- I was not allowed in the house. Neither I nor those gentlemen helping me nor my attorney were allowed in the two garages. The -- the gentlemen with me were allowed to pick up a number of items; but they were, in general, the less valuable ones. BY NBt . BOSWELL Q Are those items on this list? Are those items you picked up on this list? A No. No. Of course, they are not on the list. Q Does this recollect -- this list is your list of those things that had not yet been recovered at tre end of September? A Yes. And the reason -- the reason they weren't recovered is that Mrs. Phillips after an hour or so of this loading the truck said she had somewhere to go and the effort would have to be continued on another day. Mr. Yahn, my attorney told me, was planning to be there. But in the end he assigned -- and forgive me. I'm not an attorney -- any legal oversight of that day to my then attorney. Q You then notified Mr. Frey? 49 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That again the turning point I thought. I realized then I was in an adversarial relationship although there had been hints if it before certainly. And at that point, I did call Mr. Frey to try to be of assistance to him because I realized that for a long period of time I fe]_t I had been mistreated -- again, it's not about that time -- or misrepresented or told untruths. Q You then composed, a second list, correct? A Yes, I did. Q Is that list -- this was stipulated as part of your claim? A Yes. Q Could you identify that, please? A Yes, that's the second list. I remembered more items I did not remember on the first list, and I added them. Q And had any of those items been recovered since that time? And I asked you to identify what is that time. A What is what time? I'm sorry. Q When did you compose the second list? A In February of '09. It' s dated February 11th of '09. Q Did you send that to Mr. Frey? A Yes, I did. 50 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did you recover any of those items from Mr. Frey? A Not frcm Mr. Frey. I have recovered one item for reasons I don't understand. Q What item did you recover? A The very first item, the antique disr~lay table that my grandmother bought in France in 1906. It was returned through Mr. Yahn's office for reasons that I don't understand. I don't know why it was returned, but it was. And I have it now. Q Now, you made a claim against the Estate for return of the items? A Or compensation although some of the items could never be compensated for. I mean, they're irreplaceable. No money can make up for them. Q What items are you referring to now? A My mother is a very recognized artist in Washington. She's been an artist for 70 years. She's 97. My grandmother is -- her mother is a recognized artist. Boh of their works are in museums, and the paintings that Mrs. Stull referred to and perhaps some sculptures as well in bronze were among the items that were there, many of them. And they cannot be replaced obviously. Q Do they have a value? Are you aware of the value? 51 2 3 4 5 6 7 8 9 10 11 l2 13 14 15 16 ,~ 18 19 20 21 22 23 24 25 A No. I am not an art connoisseur or evaluator. But I know that my mother's work is in her lifetime she has probably sold at least $50,000 worth of art. She's had many shows. MR. YARN: Your Honor, I would like to object. He's speculating. He's not an art expert. THE COURT: I understand. NIlZ. GILROY: May I interrupt, Judge, and come in? THE COURT: Yes, you may. BY MR. BOSWELL: Q When these items were at 93 Encks Mill Road -- I understand these items that you are claiming were definitely at -- on -- at 93 Encks Mill Road, correct? A Absolutely. MR. YARN: Your Honor, I'm going to object. There's been nothing to provide documentation or otherwise other than -- that those items were specifically at the property. He gave a general reference to painting, but no specific painting has been identified. Ngt. BOSWELL: Your Honor, we can go through each of the items and ask if they were on the property. But my understanding is and -- could I ask just a general question and maybe we can go from there? THE COURT: Go ahead. 52 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. BOSWELL: Q In your Respondent's Exhibit 1 which was the October 23 item, to your recollection when you -- you lived at 93 Encks Mill Road, correct? A Yes, I did. Q Were all of those items on that site when you lived there? A Yes. Q Were those items there when you left that property? A They were. Q When did you leave that property? A September 9th, 2008. Q With regard to Claimant's No. 1 which is the revised list -- A That's the revised list? Q The revised list, your Claimant's No. 1, the revised list in February -- A Yes. If that's -- yes. I'm sorry. Go ahead. The February '09 list. Q Did you -- when you lived at the property, did you take those items to 93 Encks Mill Road? Were those -- in other words, were those items also at 93 Encks Mill Road? A All of them except the first, the table. 53 2 3 4 5 6 7 8 9 10 11 12 13 I4 I5 I6 17 18 19 20 21 22 23 24 25 That I had left with -- not for safekeeping but safer than I felt the apartment I lived in at the time -- this was before I moved to Encks Mill Road -- Q But that table is not part of your claim? A Not anymore. It has been returned to me, I I mean, it's on the list; but it's been returned much later, a couple of months ago. Q Now the revised list is somewhat duplicative cf the earlier list; is that correct? A Very much so. But there are some items that are not. They were added that I remembered later. There was a great deal there. Q Does the revised list include the items that were on the first list? A Oh, yeah. Yes, it does. Q Now, were the items on the revised list to your knowledge ors the property at 93 Encks Mill Rcad? A Yes. Q Were those items there when you left the property in September of 2008? A Yes. Q As to those -- A Again, the -- the table is not. Q As to everything except the table, were any of those items on the revised list, which is Claimant's No. 54 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1, returned to you? A No. Q And those are the items that -- that are the items of your claim today; is that correct? A Yes. Q When you were a resident at 93 Encks Mill. Road, did you have any of those items insured? A Not as such. I had -- no, I didn't. I have renter's insurance where I lived before. No, I didn't. I didn't. Q The artwork itself and the sculpture that you testified to, you did not have a rider or anything with regard to insurance for those items; is that correct? A Yes, that is. I'm afraid I'm a bit less than businesslike in that. Q When did Mr. Frey first tell you to make a claim against the Estate? A It would have been obviously after he discovered that the items were missing; and through him, I discovered that. And he discovered it in the second walkthrough which if my recollection -- if there's testimony definitely pinning down the time of the second walkthrough, I will revise my memory of when I spoke with him. But it would have been -- he called me and told me it was missing while he was at the Estate and the 55 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2~ J second walkthrough. It would have been shortly after that, probably within a week after that when I recovered from the shock I would have -- well, it wasn't a shock. Really, it wasn't; but I would have spoken to him shortly after that. Q When again Linda Stull aware of any items that may have -- that did belong to you? A Well, I suppose the technical answer would be in the first walkthrough when she saw the pool table and -- the pool table and other items that I believe she would have recognized as not part of the Estate or belonging to her father. But when did she communicate with me or -- Q Well, when did she have a discussion with you or when did you talk to her at any time during that time period with regard to items that belonged to you? A It would have been -- she called me -- I was driving to work. Let me think. It would have been -- that's difficult. It would have been in October, certainly obviously before the third walkthrough when I was present. It probably again the middle or the second half, early in the second half of October she called me and I called her right back. She left a message, but I called her right back. Q Did you then talk to her? A Yes. Q And did you discuss your personal property 56 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 items? A Yes. And she discussed similar correspondence -- items of concern to her. Q That were what she testified to as the Estate items of family and memorabilia? A And missing, I remember she mentioned these were items of tremendous and nostalgic meaning to he r_. She mentioned a cradle, specifically a cradle. MR. BOSWELL: I have no other questions at this time, Your Honor. THE COURT: Mr. Yahn. MR. YARN: Your Honor, may I have a moment please? THE COURT: Yes. MR. YARN: Thank you. We're all set. THE COURT: Go ahead. CROSS EXAMINATION BY MR. YARN: Q Good morning, Dr. Shapiro. I'm Neil Yahn ors behalf of Alice Phillips. A Good morning. Q Dr. Shapiro, you're familiar with Alice Phillips, are you not? A Yes. 57 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q When did you first meet Miss Phillips? A I first spoke with her in late October of 2006. Q Earlier you had referenced 93 Encks Mill Road. When did you specifically move into 93 Encks Mill Road? A March 31st, 2008. Q And when you moved in, these items you allege are missing are they reflected in Respondent Exhibit 2 -- Respondent's Exhibit 1 you have in your possession? MR. BOSWELL: Claimant's No. 1? BY MR. YARN: Q No. Respondents. The letter dated at or about October 2008 directed to Attorney Frey? A I'm sorry. Are they reflected in that letter? Q Correct. When you moved in, are those the items you brought with you? A They did not all arrive at that time. I mean, many of them did; but some of them were moved there later. But they were all there when the letter again written. Q Prior to that, where were you residing? A In Harrisburg. Q Where in Harrisburg? 58 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A In an apartment. I'm don't remember the name of the development. Anyway, it was Country Club Road. It's a -- it's a development. It's an apartment complex and housing complex off of -- my goodness. My memory is failing me. But at any rate, it's a well known one off of tTnion Deposit Road, off of Union Deposit Road. Q And how long did you reside there? A One year. Q You referenced the first time you met Miss Phillips to be October of 2006. Under what auspices did you meet her? A Under the auspices of Mr. Connelly, Mr. Yahn as filtered through Dr. Shienvold. Q So as an employee of Dr. Shienvold, you met with her as a psychiatrist? A My initial contact again I spoke with her as Dr. Shienvold told me that it was an emergency, that your office had contacted him, and would I please step intc the emergency and help. And I had leave, so I had to drive to Philadelphia with my family. So I spoke with her on the phone. That's why I say I didn't meet her that day. Q You ultimately diagnosed Miss Phillips, did you not, with regards to her psychiatric care? A Yes. Q And in fact, ycu diagnosed her with 59 2 3 4 5 6 7 8 9 10 I1 I2 13 14 15 16 17 I8 I9 20 21 22 23 24 25 depression, did you not? A I believe so. Q And you in fact diagnosed with her with IQ at or about a fourth grader, did you not? MR. BOSWELL: Your Honor, I object. I don't understand what -- the basis. I'd like to have an offer as to how his diagnosis has anything to do about claim for personal property. MR. YARN: Your Honcr, Dr. Shapiro is a psychiatrist, a licensed medical professional within the Commonwealth. If he's ultimately allowing his chattel to stay with someone who he has also then provided arl assessment of a fourth grade education, ultimately I'm providing a nexus to how this matter relates to the Da~zphi.n County Court matter. THE COURT: I'll give you some leeway. Do you want to answer the question, please? THE WITNESS: Yes, Your Honor. When I first interviewed Mrs. Phillips, I wrote that she had above average intelligence. To my shame, I yielded to pressure by -- by Dr. Shienvold, his son, and yourself and Mr. Connelly. Ycu may recall meeting in Dr. Shienvold's office -- MR. YARN: I'm going to move to strike that as unresponsive. 60 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. YARN: Q The question again, did you diagnosis Miss Phillips with an IQ of that of a fourth grader, yes or no? A A fourth grader could have a high. IQ. I hedged because I didn't -- she -- I was under -- put under pressure by yourself, Mr. Connelly, and Dr. Shienvold because they wanted her and said that she was retarded. I -- I hedged because she does have -- at that time I believed she had a fourth grade education. But she is of well-above average intelligence. Yes, I did write that and to my regret and shame. Q And in fact, Miss Phillips again under your care for a period of a year and a half to two years, again she not? A She was under my care until August of 2007, not 2008. August of 2007. Q And at that point, she was no longer under your care; is that correct? A At that point, I turned her -- I wrote a letter and turned her care over to another physician. Q You wrote prescriptions on behalf of Miss Phillips, did you not? A Yes. Q Including prescriptions for depression? 61 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q Including prescriptions for Attention Deficit Disorder? A Yes. Ngt. YARN: May I approach, Your Honor? THE COURT: Yes. BY Ngt . YARN Q If you would take a moment to examine that document? Ngt. BOSWELL: Do you have another copy of that, sir? MR. YARN: I'm sorry. I do not. BY MR. YARN: Q Do you recognize that document, Dr. Shapiro? A Yes, I do. Q And how do you recognize it? A On date entered, 9-11-07, Alice had -- actually, it would have been, yes, 9-11-07, Alice Phillips contacted me because she felt very ill. I implored her to seek medical care from the doctor I referred her to. She was often resistant to medical care. I'm talking physical medical care. But she did on my treaty go to that doctor who immediately put her in the hospital at Holy Spirit. I don't remember if I called her there or she called me, but 62 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 she asked me to come over to the hospital. She said I was the only person she could trust. And over -- and she said she wanted to dictate a will. And so I sat there for a brig while and took this at her dictation. At the end of it over my firm and repeated protestations, she made me an heir to -- to some of her estate. I didn't want to do it. The reason she did it she said again that only I understood the 11 people -- the problems of the 11 people who were totally dependent upon her because of .retardation, because of severe end stage multiple sclerosis, because of drug abuse, because of youth, because of mutism, and because of severe ADD and because of autism. She wanted me to take responsibility for those people, and she told me that if she died the next day in the procedure which she told me again mandatory, a pneocardiac cath, I was the only person she trusted to be responsible for those people. Q Okay. So you acknowledge she continued to view you in a confidential, trusted relationship'? A Yes. Q And that's in or about September of 2007? A Yes. That's the date. That's the date on -- on this. Q Again, and this is your handwriting, correct?I 63 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, it is. Q With the exception of it appears to be written in the margin. or the column rather Alice Phillips 9-12-2007. Is that her signature to the best of your knowledge. A It is. And she -- I asked her to sign every page. I believe I did or maybe she wanted to. You see the dates are different because I went there at 11:30 as it says 23 -- well, it says from 2350 on 9-11 to 12:40 on 9-12. It was the room she was in at the hospital. Q In fact, it's under this document that she left a significant portion of her estate to you outright, correct? A I haven't read it recently; but, yes, if you say so, yes. Q Well, no. Let's read it. Go to if you could please -- A She did. ShE MR. BOSWELL: THE WITNESS: MR. BOSWELL: left him. To my knowledge, So the question with regard irrelevant. did leave me -- let's see. Your Honor, I object as to -- I need to review. -- the question as what was Alice Phillips is still alive. to what was left is -- is MR. YARN: Your Honor, we're establishing the 64 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 level of control that Dr. Shapiro had over Miss Phillips. And so from that what we've established is he's drafting a document purportedly on her behalf leaving her assets ultimately in part to him. THE COURT: Are we going to get to the items of personal property? MR. YARN: We will, Your Honor. We will. THE COURT: This is the last question then. BY N.~t . YAHN Q You acknowledge this document leaves a portion of Miss Phillips residue to you? A I do. And if it please the Court, I would like to read the wording. But I would have to search for it. Yes, I acknowledge. Q Okay. A And may I indicate she trusted to care for the 11 people I referenced? Q Do you want to take a moment to review this document? A Yes. Q Do you recognize this document? A Yes, I do. Q And in fact, there's a claim filed against you in the Dauphin County Court of Common Pleas -- I'm sorry. Strike that. There has been a writ of summons 65 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 ?_2 23 24 25 filed, has there not, against you in the Dauphin County Court of Common Pleas? A Yes. Q Has a complaint been filed in that matter to your knowledge? A No. Q Has to a rule -- a rule to issue a complaint been filed. A I don't understand what that is. Q I'll rephrase. Have you required Miss Phillips to file a complaint as opposed to just a writ at this stage? A I don't know. My attorney mentioned that hi_s employer medical protective company might have pressured him to do that or he might have done it. I honestly don't know the answer to that question. Q Okay. And your attorney for purposes of that matter is not your attorney today? A That's correct. Q Who is that? A Mr. Grill. Q Could you state Mr. Grill's full name for the record, please? A I'm embarrassed to tell you I don't recall his first -- Daniel. Daniel Grill. E6 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q I'm sorry. Did you say Daniel? A Daniel Grill. Q Okay. Thank you. I'm going to direct ycur attention then back to Respondent's 1, the list of items you had the opportunity to review. It's the letter dated October of 'OS to Attorney Frey? A Yes. Q Have you provided receipts to this Court with regard to the value of those items? A Receipts? You mean purchase receipts? Q Correct. A No. Q Okay. You have averred that you have over $100,000 worth of items that are missing, correct? A Yes. Q But you haven't provided any document to support that claim, have you? A If you mean purchase receipts, no. Q Have you provided any statement of value from any expert as to this artwork that you have allegedly that's missing? A No. Q Have you provided any documentation as to an appraisal by any independent party setting forth the value or these items that are missing? 67 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q In or about you testified 9-27 of '08, you had the opportunity pick up items from the house, correct? By house, I'm referencing specifically 93 Encks Mill Road? A That's right. I thought I did. I was allowed to pick up some items, yes. Q At that time, did you take an itemized list of the items you removed? A No. Q And did you provide anyone a list of the items you removed? A Did I provide anyone with a list? Q Correct. A No. Q Okay. Are you an heir under estate of L.B. Phillips? A No. Q You're not a beneficiary? A No. Q And nor are you a relative of any of the decedent L.B. Phillips? A No. MR. YARN: Your Honor, I have nothing further at this time. MR. FALLER: Just briefly. 68 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CROSS EXAMINATION BY Ngt . FALLER Q Dr. Shapiro, did you talk to Rob Frey when you moved in in September? A In March. Q Oh, in March. I'm sorry. March of '08 you moved in. S eptember you moved out? A No. Q Okay. It's a yes or no questions. You didn't talk to Mr. Frey when you moved in in March, correct? A Correct. Q Do you know if he even knew you were there? A I don't know if he knew it or not. Q Okay. How would he have known it? A I don't know. Q Okay. A He might have observed me come in and out. Or he or miss -- I don't know. That's speculative. Q Okay. Let's not speculate. Were you aware there was a court order barring Mr. Frey and any of L.B. Phillips' children from going on the property? A Again, I'm riot an attorney. I was told that 69 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 they were not allowed there. Whether there was a court order, I don't know. Q Okay. And who told you they weren't allowed there? A Alice Phillips. Q You said you did go and try to get some of your property back? A Yes. Q Okay. A On the 27th of September. Q 2008? A Right. Q And who prevented you from getting what you claimed again all your property? A Alice Phillips. Q Mr. Frey wasn't there that day? A No. MR. FALLER: I don't have anything else. THE COURT: Anyone else have any questions? MR. BOSWELL: Yes, Your Honor. I have brief. redirect. THE COURT: Go ahead. REDIRECT EXAMINATION BY MR. BOSWELL: 70 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Dr. Shapiro, you were asked a question with regard to value of the items. On what basis did you establish these items were worth more than $100,000? Did you purchase them? What did you pay for them? A I purchased a number of them; and I attached on -- I attached -- before proposing letter of 10-8 to Mr. Frey with the accompanying list, I attached values to the items, added them up. Some of them are obviously -- people have an idea of what a Nikon SLR camera is worth. The Venetian glass, for example, was purchased by my grandmother at the World Exposition. It's very special, very special. It was Italy's choice of what to put in the Italian pavilion in the 1893 famous Chicago's World Fair, so very valuable stuff. And I went through -- some items I purchased for -- I'm just glancing at this. I think the Court wouldn't want me to take time to go item by item; but I will if that's the wish of the Court. For example, on page 2 near the middle, Snow and Nealy is a very special and old maker of axes and forest equipment. And I bought those, and I know what they cost. So some of these items I do know what they cost. Some of them I did buy. Others like a large freestanding power tools, I have an idea of what they are worth, what it would cost to replace them. You are right, I don't show that 71 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 calculation here. Q But the basis for the value next to the hundred thousand dollars is based upon in part what: you paid for them, correct? A Yes, in part. And in part, collector's value and value of art. I recognize artists whose work is in museums. Q And how did you value the collector's value? How did you -- you placed the value on that to make this claim. A I discussed it with my -- my mother and tried to remember all of the paintings and sculptures that were there which I -- and added the glass, the other collector's items, antiques. Plus -- that's the figure I came -- came to. Q So is the value of the artwork based in part on your discussions with your mother? A Yes. Q And your mother had value -- had knowledge as to what she had sold some of her artwork for? A Oh, yes . Q Same questions regard to the sculptures, were these sculptures made by your mother? A Yes. And some of the paintings I believe were by my grandmother. 72 MR. YARN: Your Honor, may I object? The 2 continued line of questioning is setting no foundation as to 3 the value of any of the property listed on this. And unless 4 they have some other independent corroborative evidence -- 5 THE COURT: An owner can testify to the value 6 of property that they -- a person owns. It doesn't mean 7 that I'm going find in favor of Claimant for the amount that 8 he's claiming, but he has a right to say what he thinks it's 9 worth. 10 BY MR. BOSWELL: 11 Q Dr. Shapiro, when -- you don't -- you don't 12 have possession of these items for which you could seek. an 13 appraisal at this time, correct? 14 A Precisely. Correct. 15 Q And -- 16 A How can I have them appraised? I don't have 17 them. 18 Q If you had the sculptures or if they were 19 provided, the sculptures and the paintings, those items 20 could be appraised, correct? 21 A And the Venetian glass, of course. 22 Q When you moved from the property, did you 23 have any intent that you were going to sell those items? 24 A Yes. Yes. Some of them. Some of them, yes. 25 Q But at that time wrien you left -- 73 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2~ 2~ 2~ 2' A In time, I would. Q Eventually? A Yes. Q You didn't -- at that time, those -- those items were yours and you intended to keep them, correct? A Some of them I intended to keep, yes. Q So -- A Most of them, I suppose. Q So when you had those items, you hadn't sought to establish a sale value at that time, correct? A No. Some of them I had for years and years. Q But what were those -- but the items that come from your mother and your grandmother, what were they worth to you? A Inestimable. You can't convert that to the dollars, but I did my best market value. To me emotionally? Q Well, we understand that they're valuable emotionally; but from a sales standpoint, what do you think they were worth? A I would want to look at my breakdown table, my breakdown figures. I don't have it with me. It's hard to answer that because there's so many things here, but I certainly think 5C at least. Q And so -- so the items that you purchased such as the trailer and the tools and the compressors and 74 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 wrenches, etc., those items that you purchased, those are the other $50,000 worth of your claim? A The 50 is a very rough, broad estimate. Yes. And I calculated this on the basis of the replacement because if I replace them, I -- I can't buy things I bought years ago. Q But you think if you replaced them that the cost to replace them knowing what items that you no longer have would be in excessive of $100,000? A No. Not the ones I could purchase. Q Okay. So would you answer that question'? A A high end Nikon SLR digital camera that was almost new, no, I don't think that -- that that would be $100,000 to replace all those. It would be sizeable. Q So would you establish you thought that the artwork and the sculpture you had a value of $50,000? A Roughly, Q The -- A It's hard to estimate that without doing a lot of arithmetic but roughly. Q Well, with regard to -- your claim with regard to the items you could purchase, not artwork and things like that, but cameras and the other items that are on your claim, is it your testimony that those items would exceed $50,000 if you were to add those items? 75 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I have to answer that I'm not certain. The~,~ -- it would be sizeable. But again, I don't have the arithmetic with me; but it would approach 50 I believe. It would be in the ballpark of that. Q So when you made your claim, it was your estimate that you -- you added these together and that's where you got $50,000 for those items and the artwork again at least $50,000? A Right. That's it. Q And is that the reason why you established your claim and said it would be in excess of $100,600 for those items? A Yes. That's right. MR. BOSWELL: No other questions. Thank you. THE COURT: Anything else? MR. YARN: Your Honor, if I may, please? RECROSS EXAMINATION BY MR. YARN: Q Dr. Shapiro, you testified you have a list that you created with regards to the damages; is that correct? A With regard to the -- Q With regard to your calculation for your damages? 76 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I may have it. believe I have it. Yes, I believe I have it. I Q And did you produce that list as part of this proceeding? A No. Q Did you provide that list today to anyone prior to coming to this hearing? A No. Q This hearing again continued from a previous date, again it not? A Yeah, I believe so. Q So you had ample time to provide that list to us, did you not? A Yes. But no one asked for it. The whole question of valuation didn't come up, I mean, item by item valuation. Q You acknowledge that you were in ari intimate relationship with Miss Phillips, were you not? A No, I was not in an intimate relationship with her. Q You never engaged in sexual relationships with Miss Phillips? A Absolutely not. Absolutely not. MR. BOSWELL: Your_ Honor, I would object. I don't think that was any place in the testimony and outside 77 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the scope of redirect for recross. MR. YARN: Nothing further, Your Honor. THE COURT: Okay RECROSS EXAMINATION BY MR. FALLER: Q We talked about when you moved in. When you moved out, that would have been September 2008? A September 9th. Q Why did you move out? A Because I realized into what a network of -- of vile lies I had been drawn. Q I didn't hear the answer. THE COURT: Of what? THE WITNESS: A network of vile lies I had been drawn. THE COURT: Vile lies. BY MR. FALLER: Q Vile lies. What do you mean by that? A It would take a long time to answer your question completely. But in brief, I was extensively, massively deceived by Mrs. Phillips in a whole -- in an immense number of ways and drawn into a web by a very intelligent master manipulator. To give one example that is in evidence, Miss Lucy's murder room again pointed out. It was Linda who 78 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was present at Miss Lucy's death. She was no more murdered than anyone in this room has been. Other deaths that -- murders that Mrs. Phillips ascribed to her late husband, tortures, tortures that he inflicted on her for years, monstrous wrongs and abuse, confining her to the, quote, time out room in the basement, depriving her of food, of bathes, of the right to drink soda, tripping her with his cane, all lies, all, all lies. MR. YARN: Your Honor, I'm going object. This line isn't relevant to the matter at hand. Moreover, some of the issues that he's disclosing are ultimately protected by and between our client and the relationship she had with Dr. Shapiro. THE COURT: Okay. MR. FALLER: How about another question? THE COURT: Go ahead. BY MR. FALLER: Q The day that you physically vacated the premises, what happened? A As I said, I realized, came to my senses. I woke up to what had happened, and I left precipitously leaving my belongings behind. MR. FALLER: I don't have anything else, Your Honor. THE COURT: Anything else? 79 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BOSWELL: No questions, Your Honor. MR. YAHN: Your Honor, can we take a brief recess? I would like the opportunity to confer with my client. THE COURT: Okay. Take a 10-minute recess. MR. YAHN: Thank you, Your Honor. RECROSS EXAMINATION BY MR. YAHN: Q Dr. Shapiro, do you have any pictures of the items in the house that you allege are on this list? A No. It never occurred to me to take any. I have a picture of the table in your office. Q But you don't have any pictures of_ the items in 93 Encks Mill Road by the house I mean? A I don't believe so, no. Q And you left in -- I just want to clarify was it September 9th of 2008? A It was -- I -- it was a decision I made over the night of the 8th to 9th. But I -- since -- the day that I definitely left again the 9th. Q Did you have a contract with the Estate to hold your property? A No. Q And did you have a contract with 80 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miss Phillips to hold any of your property that you allege again there? A No. She had invited me to keep it there saying that she had plenty of room and I would be welcome to store things there a number of which -- well -- Ng2. YARN: We have nothing further, Your Honor. THE COURT: Anything else for this witness? MR. BOSWELL: No, Your Honor. Ngt. FALLER: No, Your Honor. THE COURT: You may step down. THE WITNESS: Thank you, Your Honor. THE COURT: Is that it? MR. BOSWELL: I have no other witness. I ask for the introduction of and admission of Claimant Exhibit 1 and Respondent's Exhibit I. THE COURT: I assume you have no objection to Respondent's Exhibit 1? MR. YAHN: No. THE COURT: They're admitted. NH2. YARN: Your Honor, we so move to have our Respondent's other than Respondent's 1 moved in. MR. BOSWELL: I would object to Respondent's No. 3 as being irrelevant to the matter at hand which is the written summons in Dauphin County. 81 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: I will admit it. Anything else? Do you have anything else, sir? MR. YARN: No. THE COURT: Do you have anything to present? MR. FALLER: Just I want to make sure its in the record that possession again turned over November 8th. I don't know if that's in the record that you have from -- I think it's in the record from the prior hearings in this case because we had the hearing in New Bloomfield where you granted, I think, preliminary approval. But if need be, I will call one witness. MR. YARN: Can we clarify what you mean by possession? MR. FALLER: Possession of Encks Mill Road because there had been a prior court order barring the Executor and any of the family members. And I just want to make sure that as of that date through November 8th. And I think, correct me, if I'm right it was November 8th. NHt. YARN: I believe that to be correct. THE COURT: November 8th, 2008? NHt. FALLER: Correct . THE COURT: Okay. That's a stipulation. Everybody agrees with that, or do you want testimony to that effect? MR. BOSWELL: Agreed. 82 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Agreed? MR. YARN: I believe that to be the date, Ycur Honor. THE COURT: Okay. Will that close the testimony then? Ngt. FALLER: Yes, Your Honor. THE COURT: Do you have any arqument you`d like to make at this time, sir, on behalf of your client? MR. BOSWELL: Very briefly. We believe the claim is rather simple that Dr. Shapiro did come on the premises with permission of A1_ice Phillips. As we understand, she did have rightful possession of the premises. And thereafter when he left the premise, he did notify the Executor of his property that again on the premises of the Estate albeit in the curtilage area as we understand from the testimony again so provided to Alice Phillips. However, during that time period, the testimony will also reveal that the Executor knew of a dispute as to personal property, chiefly personal property with regard to the Estate and Alice Phillips but then also found that there was a dispute as to personal property of -- of Harvey Shapiro. During the time period of the various 83 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 inspections, it was then discovered by the Executor that not only again property removed from the -- the Estate's real property that the Estate had. a claim to but also the real property -- the personal property of Harvey Shapiro. Dr. Shapiro testified as to the value of that property based on what he paid for and what he thought the value again. He testified that he did not have ar, appraisal done because, first of all, he wasn't in possession of that to get an appraisal for this proceeding. And secondly, he didn't intend at that time to sell the property; and he had no reason to establish a market value for them at that time because he intended to recover those items which is the reason why he then contacted Mr. Frey after he was denied the ability to remove) those items the end of September 2008. So the testimony then established that sometime in October Mr. Frey did learn about this. There was a hearing. The point of contention about personal property again a known issue at that time, and Mr. Frey at that time also knew the claim of Harvey Shapiro. It was after that proceeding and after the inspections he then found that not only the property -- the personal property of the Estate had been removed from the -- triis area that had been cordoned off but also the property of mister -- of Dr. Shapiro. 84 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 It's our contention that the Executor knowing of a dispute of not only of the Estate property but also of, mister -- Dr. Shapiro's property again -- had a heightened awareness and with that heightened awareness should have done something more to protect all of the property that has since disappeared. Dr. Shapiro testified that everything again there when he left. And when he returned at the permission of the Estate, very little again still there. We understand the Estate is willing to turn over that; but that -- what is there is of really insignificant value. So it's our contention that the Estate does have responsibility and can't be an innocent responsibility because the -- the Estate knew of a dispute and should have taken steps to protect the property that was there on the real property of the Estate for which reason Dr. Shapiro made a claim. Thank you. MR. YARN: Your Honor, I'll be brief. Today, Dr. Shapiro has not presented any evidence truly setting forth what was placed within Encks Mill Road whether it be photos or otherwise other than his own testimony. He hasn't presented any other documentation or oral testimony to provide support for the list that's ultimately set forth in the documents before this Court. Other than that, there isn't anything setting forth that 85 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 these items were specifically in Encks Mill Road. Secondly and critical to the point, there's been nothing established by .way of evidence of how much ultimately each item costs. It's a blanket approach of $100,000. He claims to have done a calculation as it relates to $50,000 to artwork and $50,000 to other tangible items. But there's, again, nothing before this Court to prove his case. Even assuming those points, Your Honor, this matter is ultimately appropriately to be handled before the Dauphin County Court of Common Pleas. There's a writ currently against Dr. Shapiro. If he wants to aver, bring his rights with regards to Miss Phillips, he can do so at that time. But as it relates to this matter and the Estate, it's an inappropriate party, Your Honor; and we would, therefore, ask that the Estate be ordered to -- pursuant to the settlement agreement distribute the balance of the moneys with the exception of the damages that are currently continue to remain in dispute as it relates to 93 Encks Mill Road without certainly conceding that point. But we're agreeing that has to be handled i.n a separate forum. But there's $100,000 that they're specifically reserving for Dr. Shapiro's claim. We request this Court so order that those moneys be distributed to 86 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miss Phillips consistent with the spirit of the order originally executed on or about November of 2008 -- I'm sorry -- October of 2008, Your Honor. And they continue to this day hold those moneys premised upon the claim of Dr. Shapiro. Thank you, Your Honor. THE COURT: Uh-huh. Ngt. FALLER: Just very briefly, this is kind of like a bailor/bailee situation. And here you have them, and we're just kind of observers. It would be like if I rent a building from Mr. Frey to run an ice cream store, I lease equipment from somebody, and when I close down my ice cream shop I take the equipment. They can't go back against the landlord who didn't have possession of the property. I mean, that's what they are trying to do here. We were not in possession. We were prohibited from going into the property. Mr. Frey testified shortly after we had the hearing in New Bloomfield it came to his attention that property again going missing. We contacted Mr. Yahn's office and tried to settle that and get it done. But, you know, if -- Dr. Shapiro has a claim, it's clearly against Alice Phillips. THE COURT: Okay. Can we all agree that as of November 8, 2008, when the possession of the real estate again turned over to the Estate that Dr. Shapiro's property 87 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 again not present, again not there that he's claiming? Can we agree to that? NIl~. GILROY: With the exception of ~ahat I believe to be a treadmill and some miscellaneous personal items. THE COURT: Which will be turned over to him promptly? Ngt. FALLER: Absolutely. THE COURT: Okay. Obviously, I've been a judge throughout these proceedings. And I do recall the order that was entered because of a physical type dispute between the parties that -- well, it may not have been physical; but it was verbal. And I was afraid it was going to be -- to get physical; and I decided to enter that order. So tree Estate did not have possession of the real estate because of my order. And I agree with the Estate's attorney that without possession they don't have control over Dr. Shapiro's property, personal property until it was removed by a third party, not the Estate. Dr. Shapiro has established a claim today of personal property that he says is missing. A11 indications are that the property again removed from the real estate by Alice Phillips or her people under her control. Therefore, you're claim is against her, not 88 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the Estate, sir. I tend to agree with counsel for Miss Phillips that you have not proven the monetary value cf your claim by a preponderance of the evidence. That's the standard in a civil case. I assume that's the standard here in this case. However, those items should be returned to you especially the artwork by anyone that's in possession of those items under the jurisdiction of this Court. And by the way, Alice Phillips is under the jurisdiction of this Court and remains under the jurisdiction of this Court until all issues have been revolved, all personal property issues. So if Alice does know where those items are and if they're still in her possession or she can obtain possession of those items, I would strongly suggest that she return those items to Dr. Shapiro. However, the Estate is not responsible for either the value of those items or the return of those items. There is no -- there's no implied contract that I can think of that would require the Estate too indemnify a person who is in -- is living on -- on estate property without paying rent or anything to the Estate, without really knowledge of the Estate. I just can't think of any implied contract and there's no expressed contract where they would be 89 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 required to indemnify a person that leaves his property -- personal property under these circumstances in the custody of Alice Phillips or whoever is living there on the Estate property. I think she lived there. I believe there were other individuals living there. I'm not sure, her family members. So I'm going to deny your claim, sir, as against the Estate. But I feel you do have a claim against Alice Phillips which you can litigate either in this Court of Common Pleas of Cumberland County or perhaps in the Dauphin County matter. I'm not sure. I don't know about that. You're not the attorney for that action? MR. BOSWELL: No, Your Honor. THE COURT: So that's my decision. Any clarification needed? MR. YARN: Your Honor, may we request under the initial petition the Executors list of damages pursuant to its order dated March 24th, of '09 they listed or set aside $100,000 from this Court's original order dated October of '08. We would request that they release those proceeds consistent with the original settlement agreement. MR. BOSWELL: Can I have a moment? THE COURT: Go ahead. You can talk. I excused, Dr. Shapiro. 90 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2~ MR. FALLER: Okay. The thought that came to our mind, Your Honor, given the strength of your suggestions at the end of your decision I think we need to wait 30 days until the appeal period would pass for any order to take effect. And in that same 30 days, the itemized list of things that we said that belonged to Estate were missing include like Denault prints, cherry frames, a crock pot collection that had been in the family for 50 years, hopefully some of those things can turn up one way or another in the next 3C days in which the appeal period would run as well. THE COURT: Okay. Sounds reasonable. MR. YARN: Your Honor, may I clarify? THE COURT: Yes. MR. YARN: Just so that our understanding is this order related to solely to Dr. Shapiro's claim? THE COURT: Yes. MR. YARN: We're not handling the disputes between the marital and personal property that is so alleged on our side and also Attorney Faller? THE COURT: No. We're going to talk about that next. Would you like to be excused, or do you want to remain? MR. BOSWELL: Yes, Your Honor I would like tol 91 3 4 5 6 7 a 9 10 11 i2 14 15 16 17 . Q 1 20 21 22 G _. 92 ERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. r ~ ~ %~ ~Ia~idy"L. Cortez, RPR Official C~g'urt Reporter The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. Date C. Joseph Rehkamp, S.J. 41st Judicial District Specially Presiding 93