HomeMy WebLinkAbout04-16-12IN THE COURT OF COMMON PLEA~,
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ESTATE OF LIZA D. CHANCE OF CUMBERLAND COUN'1~~ ~:~ x,
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OBJECTIONS OF PIPPA S. CALLAND TO
PETITION FOR ADJUDICATION AND FIRST AND FINAL ACCOUNTING
OF STUART RINGER EXECUTOR OF ESTATE OF LIZA D. CHANCE
Pippa S. Calland, ("Pippa") beneficiary of the Estate of Decedent Liza D. Chance,
hereby objects to the Petition for Adjudication/Statement of Proposed Distribution
Pursuant to Pa. O.C. Rule 6.9 (the "Petition") and the First and Final Account (the
"Account") of Stuart Ringer, Executor of the Estate of Liza D. Chance, and in support
thereof avers as follows:
BACKGROUND
1. Liza D. Chance (hereinafter "Liza" or "decedent") was married to Edward
C. Chance, III.
2. Liza was estranged from her spouse.
3. During her lifetime, Liza established her residence with Pippa at 511 W.
Main Street, Mechanicsburg, Cumberland County, Pennsylvania.
4. Liza's mother, Janice Sutton, helped her to move into Pippa's home at 511
W. Main Street in Mechanicsburg.
_~
15. At the time of her death, Liza owned real and personal property with her
estranged spouse as tenants by the entireties, and those items would have passed to her
estranged husband by operation of law.
16. Letters Testamentary were granted to Stuart Ringer on May 26, 2010.
17. Stuart Ringer, Executor of the Estate of Liza D. Chance is represented by
Thomas S. Beckley, Esquire, of the law firm of Beckley & Madden.
18. On March 16, 2012, the First and Final Accounting of Stuart Ringer,
including a Schedule of Proposed Distribution, was filed for Audit with the Orphans'
Court Division of the Court of Common Pleas of Cumberland County, Pennsylvania.
19. The Schedule of Proposed Distribution reflects distributions to residuary
beneficiaries, Stuart Ringer and Janice Sutton, but no distribution to residuary
beneficiary, Pippa Calland.
20. A footnote to the Schedule of Proposed Distribution states:
Item III of the Will provides that Stuart Ringer and Pippa
Calland are to divide equally Decedent's personal items.
After making a brief inspection, Mr. Ringer determined
that numerous items were missing, and he was not provided
the opportunity to share in one-half of the Decedent's
personal items. As a consequence, Ms. Calland's share of
the residue (20% or $1,416.87) is being divided between
the Decedent's parents.
Proposed Distribution to Beneficiaries, p.8, n.3. (Emphasis added).
21. The distributive shares proposed to be distributed to Stuart Ringer and Janice
Sutton do not comply with the explicit provisions of Item IV of decedent's Will.
22. On March 19, 2012, counsel for the Executor filed an Amended Proposed
Distribution to Beneficiaries form with the Cumberland County Orphans' Court.
23. The Amended Schedule of Proposed Distribution reflects distributions to
residuary beneficiaries, Stuart Ringer and Janice Sutton, but, again, reflects no
distribution to residuary beneficiary, Pippa Calland.
24. A footnote to the Amended Proposed Distribution states:
Item III of the Will provides that Stuart Ringer and Pippa Calland are to
divide equally Decedent's personal items. After making a brief
inspection, Mr. Ringer determined that numerous items were missing, and
he was not provided the opportunity to share in one-half of the Decedent's
personal items. As a consequence, Ms. Calland's share of the residue
(20% or $1,416.87) is being divided equally between the Decedent's
parents.
Amended Proposed Distribution to Beneficiaries, p.8, n.3. (Emphasis added).
25. The distributive shares proposed to be distributed to Stuart Ringer and Janice
Sutton under the Amended Proposed Distribution Schedule are not in accordance with the
explicit provisions of Item IV of decedent's Will.
26. The Account will be presented for audit, confirmation and distribution on
Apri124, 2012 at 9:00 a.m.
27. Objections must be filed on or before 9:00 a.m. Apri124, 2012.
4
OBJECTIONS TO THE PETITION FOR ADJUDICATION
28. Pippa Calland objects to Paragraph 9 A. of the Petition in that no interest of
the named parties in interest is reflected in the Petition.
29. Pippa Calland objects to Paragraph 12 of the Petition reflecting a payment
for Pennsylvania inheritance tax of $750.00 but which fails to reflect the interests upon
which it was paid.
30. In the instant case, there are different classes of beneficiaries and the
Pennsylvania inheritance tax would have been computed at different percentages.
31. Counsel for Pippa Calland has obtained a copy of the Pennsylvania
inheritance tax return from the office of the Register of Wills of Cumberland County.
See Exhibit "A" attached hereto.
32. The Pennsylvania Inheritance Tax Return, Schedule J, lists Pippa Calland's
share of decedent's Estate as: "1/2 personalty, 20% residuary", and the inheritance tax
due was calculated on the basis of Pippa Calland receiving her 20% residuary share. The
$750.00 payment reflected in Paragraph 12 of the Petition for Adjudication reflects the
amount paid during the discount period, but does not reflect the actual tax liability of
$331.70 after the $434.89 refund is applied.
33. Schedule E of the Pennsylvania Inheritance Tax Return lists no items of
personal property other than bank accounts, proceeds from stock and the 2005 Acura
automobile.
5
38. Pippa Calland disputes that Stuart Ringer "was not afforded the opportunity
to share in one-half of the Decedent's personal items" as set forth in footnote 3 of the
original and amended Schedules of Proposed Distribution.
39. In addition, because the decedent's Will, prepared by the law firm of
Beckley & Madden, contains no provision for the payment of decedent's just debts, Pippa
Calland was forced to disclaim her right to receive the automobile specifically
bequeathed to her under Item III of decedent's Will because the car was encumbered in
an amount in excess of its fair market value.
40. Pippa Calland asserts that when it became evident that Liza's health was
failing, Liza's mother, Janice Sutton, removed all of the jewelry that had any value and
the basket collection from the residence Liza shared with Pippa.
41. Items of tangible personal taken by or given to decedent's mother prior to
decedent's death did not belong to the decedent at the time of her death.
42. Contrary to the statements contained in correspondence dated November 30,
2011 from Mr. Ringer's counsel to Ms. Calland's counsel, there is no evidence that the
tangible personal property belonging to decedent at the time of her death had a value of
approximately $1,500 which is, coincidentally, almost exactly equal to Ms. Calland's
specifically bequeathed twenty percent (20%) residuary share. See Exhibit "B" attached
hereto.
43. By correspondence dated December 8, 2011, Ms. Calland's counsel
informed Mr. Ringer's counsel that Ms. Calland objected to the distribution of decedent's
7
Estate in the manner outlined in the November 30, 2011 letter. See Exhibit "C" attached
hereto.
44. After making his "brief inspection," Mr. Ringer specifically requested and
has received several items of personal property, including a cookie jar, a silver caviar
bowl and two shotguns, none of which are included in the Petition or Account as having
been distributed to Mr. Ringer in fulfillment of Item III of decedent's Will.
45. Neither the Petition nor the Account, including the Amended Schedule of
Proposed Distribution, should be confirmed because the residue of decedent's Estate is
improperly allocated between her parents, Stuart Ringer and Janice Sutton, to the
detriment of residuary legatee Pippa S. Calland.
46. Neither the Petition nor the Account contains any documentation as to how
the Executor arrived at the fair market value of additional, unidentified tangible personal
property which he claims he is entitled to receive under Item III of decedent's Will.
47. There is no evidence that the "approximate value" of the allegedly missing
personal property of decedent is equal to Ms. Calland's twenty percent (20%) residuary
share.
48. None of the powers of the Executor outlined in Item V of decedent's Will
permits the Executor to unilaterally rearrange the residuary share percentages or to
eliminate a residuary beneficiary completely.
49. The explicit language of decedent's Last Will and Testament must be
enforced. See, Maginn's Estate, 278 Pa. 89, 122 A.264 (Pa. 1923) ("there is no right of
8
man more seriously regarded or more jealously protected than the right to legally dispose
of his property as he wishes after death.")
50. Any distribution omitting the twenty percent (20%) residuary bequest to
Pippa Calland is improper and must not be confirmed.
51. Insofar as the objections set forth herein are questions of law which may be
decided by this Honorable Court in accordance with C.C.O.C.R. 6.10-2 (a), the
appointment of an auditor is not required.
52. If, in the opinion of this Honorable Court, the appointment of a neutral
auditor is appropriate, Pippa Calland would welcome such appointment.
WHEREFORE, Pippa S. Calland requests this Honorable Court to sustain her
objections, award to her the twenty percent (20%) residuary share bequeathed under
decedent's Last Will and Testament, and grant such other relief as this Court deems
appropriate.
Respectfully submitted,
/ 7'~_.
Date: April 13, 2012 ~-~~--
Linda lsen, Esquir
Attorney I.D. No. 92858
HAZEN ELDER LAW
2000 Linglestown Road
Suite 202
Harrisburg, PA 17110
(717) 540-5443
lolsen(a~hazenelderlaw.com
Attorneys for Objector, Pippa S. Calland
9
VERIFICATION
I, PII~ S. CALLAND, verify that I am the Objector in the foregoing document
and that the facts set forth therein are true and correct to the best of my knowledge, information
and belief, and that this Verification is made subject to the penalties of 18 Pa. C.S.A. § 4904
relative to unsworn falsification to authorities.
Date: April ~~ , 2012 /~~,~ ft- ~~//
Pippa S. Calland
EXHIBIT "A"
` J ~ (o,_,al 1505610143
REV-15fl0
~
PA Department of Revenue OFFICIAL USE ONLY
Pennsylvania
Bureau of Individual Taxes county cone ve.r FAe N~miwr
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Po eox.2aoso~ INHERITANCE TAX RETURN 2 1 1 0 0 0 5 4 5
Har!isburg, PA 17128-0601 RESIDENT DECEDENT
ENTER DECEDENT INFORMATION BELOW
Social 5eeurity Number Date of peach Date of Birth
05 23 2010 12 23 1965
Decedent's Laat Name Suffix Decedent's First Name MI
CHANCE LIZA D
(ff Applicable) Enter Surviving Spouse's Information Below
Spouse's Mat Name Suffix Spouse's First Narpe MI
CHANCB EDWARD C
Spouse's Social Security Number
THIS RETURN MUST BE FILED IN DUPLICATE WITH THE
REGISTER OF WILLS
FILL IN APPROPRIATE OVALS BELOW
® t. Orlpktal Return ^ 2. Suppbmental Retum ^ 3. Remainder Retum (date of death
prior m 12-13•tI2)
^ 4. LAnited Estate ^ 4a. Future ~~ ComprmYw ^ 5. Federal Fatale Tax Retum Required
(aNe or aeNh NW 12-12-82)
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® 6, G.eederll DiNr Tntats f •1 7. Doo.QafQ Mafnt.Yrd ^ LWig Tnrl
a r.~~ u.....w....r c..b
eeil$ellee
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^ 0. Litigatbn Proceeds Received ^ ([
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10. he~P237~1 ~ T-t~~ dsNh ^ t t • E ~ tax under Set. 917 s(A)
(Attach Seh. 0)
CORRESPONDENT -THIS SECTION MUST BE COMPLETED. ALL CORRESPONDENCE AND CONFIDENTIAL TAX INFORMATION SHOULD 8E DIRECTED TO:
Mama
Daytime Telephone Number
THOMAS 3 BECRLBY 717 233 7691
First litre of address
212 NORTH THIRD STRBET
Second line Of address
City tx Post Offlce
HARRISBURG
State ZIP Code
PA 17101
REGISTER OF USE ON~
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CorrespondenYse-maUaddress: bACkst~pa.net
Under Penaltlee d perjury, l declare that 1 have examined this rofum, kidudinplaeoompanykq sr~eruiee snd statements. arW 11oo flw l~at d my knawledpe and t»Nef,
it re cotreU and txxnplNe. Declaration of preparer other than the Persona ropreeentative Is ba on all infomtation rN whleh preperet has arty krto~wlsdge.
SIGMA OF R RESPONSIaLE FOR FILING RETURN ~~
t~s~ _ ~ _ Stuart Ringer j -a ~ - I i
307 Gienn Foroet Road, Magnolia, DE 18862
Thomas S Beckley
DATE
ADDRESS -- - -
212 Notth.Third Street, Harrisburg, PA 17101
Side 1
L, 1505610143 1505610143 J
J 1505610243
REV-1500 EX
Decedent's Social Security Number
o~ca.nr: wms: CHANCE , L I Z A D.
RECAPITULATION
1. Real Estate (Schedule A) .......................................................................................... 1.
2. Stocka and Bonds (Schedule B) ............................................................................... 2.
3. Cbsely Held Corporation, Partnership or Sole-Proprietorship (Schedule C).......... 3.
4. Mortgages ~ Notes Receivable (Schedule D) .......................................................... 4.
26,582.93
5• Cash, Bank Deposits b Miscellaneous Personal Property (Schedule E) ................ 5.
6. Jointly Owned Properly (Schedule F) ^ Separate Billing Requested ............. 6.
7. Inter-Vivos Transfers 3 Miscellaneous Non-Probate Property
t
d
Billi
R 0 . 0 0
.............
eques
e
ng
(Schedule G) ^ Separate 7,
2 6, 5 8 2. 9 3
8. .......................................
Total Gross Assets (total Lines 1-7) ................................ 8.
10,068.30
9. Funeral Expenses ~ Administrative Costa {Schedule H) ......................................... 9.
10. ___
Debts of Decedent, Mortgage Liabil(ties, d. Liens (Schedule I) ................................ _
10. __ ~
21,557.11
11. Total Deductions (total Lines 9 b 10) ...................................................................... 11.
5,025.82
12. Net Value of Estate (Line 8 minus line 11) ............................................................. 12.
13. Gharilabla and Governmental Bequests/Sec 9113 Trusts for which
an eledion to tax has not been made {Schedule J) ................................................. 13.
5,025.82
14. Nst Value Subject to Tax (Line 12 minus Line 13) ................................................. 14.
TAX COMPUTATION -SEE INSTRUCTIONS FOR APPLICABLE RATES
15. Amount of Line 14 taxabb
at the spousal tax rate, or
transfers under Sec. 9116
(a)(1.2) X .00 15.
16. Amount of Line 14 taxable
4, 0 2 0. 6 6
16 1 8 0 . 9 3
at lineal rate X .045 .
17. Amount of tine 14 taxable
at sibling rate X ,12 17.
tt3. Amount of Line 14 taxable 1 , 0 0 5.16 18 15 0 . 7 7
at collateral rate X .15 .
19. Tax Due ............................... .......................,.........................
..................................... 19.
331.70
20. FILL IN THE OVAL IF YOU ARE REQUESTING A REFUND OF AN OVERPAYMENT.
Side 2
1505610243 1505610243 J
REV-1500 EX Page 3 File Number 21 - 10 - 00545
Decedent's Complete Address:
Chance, Liza D.
STREET ADDRESS
511 West Maln Street
CITY
Mechanicsburg STATE
PA ZIP
17055
Tax Payments and Credits:
1. Tax Due (Page 2, Llne 19) (1) 331.70
2. Credits/Payments -
A. Prior Payments 750.00
B. Discount 16.59
Total Credits (A + e) {z) 766.59
3. Interest
(3) 0.00
4. If Line 2 is greater than Line 1 ;Line 3, enter the difference. This is the OVERPAYMENT. (4) 434.88
Check box on Page 2 Llns 20 to request a refund
5. ff Line 1 + Llne 3 is greater than Line 2, enter the difference. This Is the TAX DUE. (5>
Make Check Payable to: REGISTER OF WILLS, AGENT.
PLEASE ANSWER THE FOLLOWING QUESTIONS BY PLACING AN "X" IN THE APPROPRIATE BLOCKS
1. Did decedent make a transfer and: Yss No
a. rotain the use or income of the property transferred :.................................................................................. x
b. retain the right to designate who shall use the property transferred or its income :.................................... x
c. retain a reversionary interest: or .................................................................................................................. x
d. receive the promise for life of either payments, benefda or care? .............................................................. x
2. If death occurrod after December 12, 1982, did decedent transfer properly within one year of death without
receiving adequate conaideration? ....................................................................................................................... ^
3. Dld decedent own an "in trust for" or payable upon death bank axount or security at his or her death?......... ^ ^x
4. Did decedent own an Individual Retirement Account, annuity, or other non-probate property which
contains a beneficiary designatlon? ...................................................................................................................... 0 ^
IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS 18 YES, YOU MUST COMPLETE SCHEDULE G AND FILE IT AS PART OF THE RETURN.
For dates of death on or after July 1, 1994 end beforo Jan. 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving
spouse is 3 percent (72 P.S. §9116 (a) (1.1) (i)).
For dates of death on or after January 1, 1995, the tax rats imposed on the net value of transfers to or for the use of the surviving spouse is 0 percent
p2 P.S. §9116 (a) (1.1) (ii)]. The statute does not exempt a transfer to a surviving spouse from tax, and the statutory requirements for daclosuro of
assets and flling a tax rofum are still applicable even ff the surviving spouse is the only beneflciary.
For dates of death on or after July 1, 2000:
• The tax rate impo~d on the net value of transfers from a deceased ch1k121 are of age or younger at death to or for the use of a natural paront, an
adoptive parent or a stepparent of the chikf is 0 percent p2 P.S. §9116 (a) (1.2)].
• The tax rate imposed on the net value of transfers to or for the use of the decedent's lineal benefiaaries is 4.5 percent, except as noted In
72 P.S. §9116 1.2) (72 P.S. §9116 (a) (1)].
• The tax rate imposed on the net value of transfers to or for the use of the decedent's siblings is 12 percent (72 P.S. §911!3 (a) {1.3)I. A
sibling is defined under Section 9102, as an individual who has at least one parent in common with the decadent, ether y blooodd or adoption.
COMMONWEALTH OF PENNSYLVANIA
INHERITANCE TAX RETURN
RESIDENT DECEDENT
SCHEDULE G
INTER-VIVOS TRANSFERS 8
MISC. NON-PROBATE PROPERTY
ESTATE OF Chance, Liza D. FILE NUMBER
21 - 10 - 00545
This schedule must be completed and filed if the answer to any of questions 1 through 4 on osae 2 is ~~^
ITEM
NUMBER DESCRIPTION OF PROPERTY
Ir>cluoe IM rwme d °is IfafllferN, °»v relatanstuP to decedern
arM the Hale M vanefer. Attach a
Dopy °f the Csed for nM estate. GATE OF DEATH
VALUE OF ASSET '>6 OF
DECD'S
INTEREST
E)(ct-USION
(IF APPLICABLE)
TAXABLE VALUE
1 Individual retirement account (decedent was under ~ss,ooo.o0 100% 169,000.0 ~ 0.00
age 59 1/2 and not disabled)
i
TOTAL (Also enter on line 7, ReCapftulation} ~ 0.00
SCHEDULE E
CASH, BANK DEPOSITS, ~ MISC.
°ON'TMOF°E"''g~~""" PERSONAL PROPERTY
IMrRRANCE TN(RETVRN
RESIDOIf DECEDENT
ESTATE OF FILE NUMBER
Chance, Liza D. 21 - 10 - 00545
surv von p must tie disclosed on schedule F.
ITEM DESCRIPTION VALUE AT DATE OF
NUMBER DEATH
1 Members 1st checking account 17,782 00
2 2005 Acura TL Autmobile 6,000.00
3 Belco savings account 914.23
4 Member's 1st checking account 1,393.39
5 Proceeds from MetLife stock 483.31
~ TOTAL (Abo enter on Line b, Recapitulation) ~ 26,582.93
COMAONMIEALTH OF PEMiBYWAlMA
11MIEItlTANCE TAl( RETVRN
REBIDEtlT DECEDENT
ESTATE OF Chance, Liza D.
S~DIa.E H
FI~QA~L~E~XPE~F.~ ~
~~ r rv~~
FILE NUMBER
21-10-
Debts of decedent must be reported on Schedule I.
ITEM
NUMBER FUNERAL EXPENSES: DESCRIPTION AMOUNT
A. 1 Myers Funeral Home 3,078.00
Mechanicsburg, Pennsylvania
2 Reception following funeral 1,063.93
B.
1.
2.
3.
4.
5.
6.
7.
1
ADMINISTRATIVE COSTS:
Personal Representatlve'a Commissions
Name of Personal Representative(s)
Stuart Ringer
street Address 307 Glenn Forest Road
City Magnolia state DE zip 19962
Year(s) Commission paid
Attorney's Fees Beckley & Madden
Famiy Exemption: (If decedent's address is not the same as claimant's, attach explanation)
Claimant
Street Addreaa
City State Zip
Relatlonshlp of Claimant to Decedent
Probate Fees Cumberland County Register of Wills
Accountant's Fees
Tax Return Preparer's Fees
Other Administretive Costs
Cumberland Law Journal
2,000.00
2,500.00
123.50
75.00
TOTAL (Also enter on Itne 8, Recapitulation) 10,068.30
COMMONWEALTH OF PENNSYLVANIA
INHERITANCE TAX RETURN
RESIDENT DECEDENT
Sc:F~edu~ H
w ~,~,F~{u,, te~ralYE~e 8
I"~i 1 w If~Y~1111c
Page 2 of Schedule H
SCHEDULEI
~~` DEBTS OF DECEDENT, MORTGAGE
CO1"MON`"~"`TM0~"~''"sY`y""'" LIABILITIES, & LIENS
NFIERRAfJDE TAX NETURN
RESIDENT DECEDENT
F~TATE OF FILE NUMBER
Chance, Liza D. 21 - ~ o - 00545
Report debts incurred by the decedent prior to death that remained unpaid at the date of death, including unreimbursed medical expenses.
ITEM ""-
NUMBER DESCRIPTION AMOUNT
1 Autmobile car loan 9,000.00
2 Beckley & Madden (legal fees incurred during Ms. Chance's lifetime) 2,488.81
J TOTAL (Also enter on Line 10, Recapitulation) I 11,488.81
REV-u~a Ex.lt~-0el ~ ~-
SCHEDULE J
COMMONWEALTH OF PENNSYLVANIA
INt1ERITANCE TAX RETURN BENEFICIARIES
RESIDENT DECEDENT
ESTATE OF
Chance, Liza D. FILE NUMBER
21 - 10 - 00545
NUMBER
NAME AND ADDRESS OF PERSON(S) RELATIONSHIP TO
DECEDENT SNARE OF ESTATE
(Words) AMOUNT OF ESTATE
(BSS)
RECEIVING PROPERTY oo Not Ua rnnc..lsl
I, TAXABLE DISTRIBUTIONS [include outright spousal
distributions and transfers
under Sac. X116 (a) (1.2)]
1 Pippa Calland Friend 1/2 personalty, 20%
511 West Main Street residuary
Mechanicsburg, PA 17055
2 Janice Sutton Mother 50% residuary
15 Cake Road
Bridgeton, NJ 08302
3 Stuart Ringer Father 1/2 personalty, 30%
307 Glenn Forest Road residuary
Magnolia, DE 19962
Enter doNar amounts for distributions shown above on lines 15 through 1 S on Rev 1500 rover sheet, as appropriate.
Ij~ NON-TAXABLE DISTRIBUTIONS:
A. SPOUSAL DISTRIBUTIONS UNDER SECTION 9113 FOR WHICH AN ELECTION TO TAX IS NOT TAKEN
~I B. CHARITABLE ANp GOVERNMENTAL DISTRIBUTIONS
TOTAL OF PART 11-ENTER TOTAL NON-TAXABLE DISTRIBUTIONS ON LINE 13 OF REV-1500 COVER SHEET 0.00
EXHIBIT "B"
BECKLEYc~ MADDEN
ATTOxNEYS aT Law
CRANBERRY COURT
212 NORTH THII2D .STREET
POST OFFICE BO% 11998
HARRTSBUR(~, PENNSYLVANIA 17108-1998
P80NE: (7171433-7891
FAR: 17171833-3740
E-D1AILs }.19CICIC~~18-OCY
November 30, 2011
Marielle F. Hazen, Esquire
Hazen Elder Law
2000 Linglestown Road, Suite 202
Harr shnrR P ~ 17110
Re: Estate of Liza D. Chance, deceased
Dear Ms. Hazen:
FILE NO.
50901
In response to your letter dated November 21, the Estate was successful in its lawsuit
against Edward Chance for one-half of the income tax refund and the matter has been resolved.
The I=,state~s~~now in a position to distribute the remaining assets. As you may recall, Ms.
(~h~nce's °~"iil directed that her personal belongings be divided equally between Ms. Calland and
1-,er father, VIr. Ringer. Mr. Kinger was able to retrieve a few; }i~~~inclu,~itlgFS? cookie jar (which
belonged to his grandmother) and a bowl (which belonged to~ his mother), `bait Ms. Calland took
most of the remaining items. Mr. Ringer is particularly concerned about the ring and a diamond
necklace which were to remain in his family. We understand that. Ms. Calland is now claiming
that Ms. Chance gave the ring to her, but we have no evidence to support this.
Uiven that Mr. Ringer did not receive one-half of his daughter's assets as her Will
provides, it is his intent, as Executor, to distribute Ms. Calland's share of the residuary estate to
himself. This amount is approximately $1,500.00 (or twenty percent of the residuary), and. we
l~~iie'.'/: iE~S Li,Gli the vaitle of or.e^half ~f tle pvrsoraltV,
If you have any further questions, please do not hesitate to contact me.
Very truly yours,
--~~ -.
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EXHIBIT "C"
Haz~v Ein~x LAw
Estate Planning • Elder Law • Special Needs Planning
2000 Linglestown Road
Suite 202
Harrisburg, PA 17110
December 8, 2011
Thomas S. Beckley, Esq.
Beckley & Madden, Attorneys At Law
Cranberry Court
212 North Third St.
P.O. Box 11998
Harrisburg, PA 17108-1998
RE: Estate of Liza D. Chance
Dear Mr. Beckley:
Tea.: (717J 5444332
enx: (717) 540-4313
www. HazenEld erLaw.com
FILE
We are in receipt of your correspondence dated November 30, 2011. Please be advised
that Ms. Calland objects to distribution of the estate in the manner you outlined. As such, we
anticipate you will prepare and file a full and final accounting of the estate.
If you have any questions, please feel free to contact me.
Sincerely,
Marielle F. Hazen
MFH/cew
cc: Pippa Calland
~ ~~ IN THE COURT OF COMMON PLEAS
ESTATE OF LIZA D. CHANCE OF CUMBERLAND COUNTY,
Deceased :PENNSYLVANIA
ORPHANS' COURT DIVISION
21-10-0545
CERTIFICATE OF SERVICE
I, LINDA J. OLSEN, Esquire, hereby certify that a true and correct copy of the
Objections of Pippa S. Calland to Petition for Adjudication and First and Final
Accounting of Stuart Ringer, Executor of the Estate of Liza D. Chance was served upon
the following parties-in-interest by first class mail on April /3 , 2012.
Counsel for Stuart Ringer:
Thomas S. Beckley, Esquire
Beckley & Madden
212 North Third Street
Harrisburg, PA 17101
Janice Sutton
15 Cake Road
Bridgeton, NJ 08302
Date: April 13, 2012 ~..~,o~
Linda J. lsen, Esqu'
Attorney I.D. No. 92858
HAZEN ELDER LAW
2000 Linglestown Road
Suite 202
Harrisburg, PA 17110
(717) 540-5443
to lsen(a~hazenelderlaw. com
Attorneys for Objector, Pippa S. Calland