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IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF
GEORGE F. DIXON, JR. :ORPHANS' COURT DIVISION
DECEASED No.21-1994-0754
IN RE: : IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF
LOTTIE IVY DIXON :ORPHANS' COURT DIVISION
DECEASED No.21-07-0686
OBJECTIONS OF MARSHALL DIXON,
EXECUTOR OF THE ESTATE OF LOTTIE IVY DIXON
TO THE AUDITOR'S REPORT AND RECOMMENDATIONS
TO THE HONORABLE JUDGES OF THE CUMBERLAND COUNTY COURT OF
COMMON PLEAS, ORPHANS' COURT DIVISION:
Pursuant to C.C.O.C.R. 8.7-2, Marshall Dixon, in his capacity as Executor of the Estate
of Lottie Ivy Dixon (the "Executor" or "Marshall"), files the following objections to the Auditor's
Report and Recommendations dated May 23, 2012 (the "Auditor's Report").
First Objection
The Executor objects to the Auditor's Report to the extent that it did not award attorneys'
fees for the Brothers' vexatious conduct in asserting and pursuing meritless objections to the
Estate Accounting, including the objection to the valuation of the Decedent's personal property
and jewelry, the objection to the allocation of the Unified Tax Credit, and the objection to the
Estate's retention of a portion of a federal tax refund. As to these objections, the Auditor found
as follows:
• that the valuation of the personal property and jewelry would have had no effect on the
distribution of the Estate assets, that the Brothers never gave any basis for questioning the
professional appraisal of those items that the Executor obtained, and that the Brothers
never obtained their own appraisal despite representing to the Auditor that they would do
so. (Auditor's Report, Findings of Fact, ¶ 20-23).
• that the Brothers never explained a factual or legal basis for their objection to the
allocation of the Unified Tax Credit and that the Unified Tax Credit was allocated as
required by the Internal Revenue Code, state law, and as set forth in the Decedent's Will.
(Auditor's Report, Findings of Fact, ¶ 24-25).
• that the Estate retained a portion of the federal tax refund due to the QTIP as a set off
against the income that the QTIP owed to the Estate and that the Brothers had refused to
pay from the QTIP to the Estate and that the Brothers never provided any factual or legal
basis for the objection to this set-off. (Auditor's Report, Findings of Fact, ¶ 26-29).
The Auditor also found that these objections increased the attorneys' fees incurred by the
Executor. (Auditor's Report, Findings of Fact, ~ 132).
These findings by the Auditor support an award of fees to the Executor as a sanction for
the Brothers' vexatious conduct. The Auditor, however, stated as follows:
The auditor concludes that it was not unreasonable for the Brothers to raise the
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questions that they raised in their objections to Estate Accounting at the time that
they raised them and to pursue discovery with respect to those issues. ...the
auditor does not find that there was anything about their pursuit of those claims
that reflected a determination to stubbornly ignore reality, to pursue a sole
purpose of causing annoyance or to cause additional legal work. (case citations
omitted).
(Auditor's Report, p. 26). In drawing this conclusion, the Auditor erred as to the facts and the
law. At the time that the Brothers asserted these three objections, they already had sufficient
facts to know that these objections had no merit and would not alter the distribution of the Estate.
The Brothers' pursuit of these frivolous objections increased the attorneys' fees incurred by the
Executor because his counsel sought discovery related to those objections, conducted legal
research on the objections, prepared to defend those objections, and addressed the objections in
pre-hearing memoranda. Therefore, the facts warranted an award of attorneys' fees to the
Executor as a sanction for the additional work that was necessitated by the Brothers' vexatious
conduct in asserting and pursuing those meritless objections.
Second Objection
Marshall objects to the Auditor's Report and Recommendations to the extent that it did
not award attorneys' fees for the Brothers' dilatory conduct during the pursuit of their objections.
The Auditor found various facts showing the Brothers were dilatory in conducting their
investigation into the Decedent's estate. Because of the Brothers' dilatoriness, the Executor made
several requests for a timeline for the resolution of the Brothers' Objections and filed a motion to
establish a discovery deadline. (Auditor's Report, Findings of Fact, ¶ 10, 37). The Auditor also
found that, after the close of discovery, the Brothers moved for an extension of the discovery
deadline, which resulted in the Executor having to oppose that motion and participate in a
discovery conference and which increased the attorneys' fees incurred by the Executor.
(Auditor's Report, Findings of Fact, ¶ 53-55, 133).
Despite these findings of fact, the Auditor stated the following:
Moreover, when the Brothers were slow in pursuing discovery, the Estate was not
incurring attorneys fees because nothing was happening in the case, in general. The
Estate does not identify any particular amounts of time that were incurred, prior to
February 9, 2010, as a result of the delays or that that the Estate was materially
prejudiced as a result of the delays. Accordingly, the auditor does not recommend an
aware of attorney fees for the fees incurred by the Estate prior to the February 9, 2010,
supplemental pre-hearing memorandum of the Brothers.
(Auditor's Report, p. 27).
In so ruling, the Auditor erred as a matter of fact and law.
While the Auditor recognized the Brothers' dilatory conduct and noted the efforts that the
Executor undertook to address that conduct, the Auditor did not award fees to the Executor for
the work that was necessary to address the Brothers' dilatoriness. Such fees include the time that
the Executor's counsel invested in exchanging communications in an effort to get the objections
on a timeline and the time that the Executor's counsel incurred in order to draft the motion
requesting that the Court establish a discovery schedule, which time would have been
unnecessary had the Brothers complied with the discovery timeline that they themselves had set.
Additionally, the Executor had to respond to the Brothers' motion to extend the discovery period
and attend a discovery conference to address that motion, which work resulted from the fact that
the Brothers were dilatory in completing discovery during the discovery period. The time
invested in these tasks by the Executor's counsel was reflected in the invoices submitted at the
hearing as Exhibit 14. The Auditor also erred in applying the law to the facts by ruling that,
despite the Brothers' dilatory conduct, the Executor was not entitled to recover the additional fees
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that it incurred. Given the facts established in this matter, the Auditor should have awarded
additional attorneys' fees to the Executor because of the Brothers' dilatory conduct.
Third Objection
The Executor objects to the Auditor's Conclusion of Law refusing to award Attorneys'
Fees to the Executor that were incurred as a result of the Brothers' appeal of the denial of the
Petition for Appointment of Administrator Pro Tem. That Conclusion of Law states as follows:
Conclusion of Law, ¶ 2:
The Orphans' Court division does not have the authority to award attorney fees for
legal work in opposition to an appeal that was either dilatory, obdurate, or
vexatious or that was frivolous for any other reason.
(Auditor's Report, p. 32). The Auditor's conclusion and recommendations in this regard
misapplies existing law and misapprehends the basis for the Executor's request to recover
attorneys' fees related to the appeal.
The Auditor ruled that the fees incurred by the Executor during the appeal of the Petition
for Administrator Pro Tem could only be awarded by the Superior Court pursuant to Pa. R.A.P.
2744 citin Mellon Bank v. Druzisky, 800 A.2d 955 (Pa. Super. 2002). Under Ambrose v.
Citizens Nat Bank of Evans City, 5 A.3d 413 (Pa. Super. 2010), however, the attorneys' fees
incurred by the Executor as a result of the appeal did not have to be awarded by the Superior
Court. In Ambrose, the Superior Court ruled that if there is a statutory basis for the award of
fees, then the trial court can award fees that were incurred during an appeal In the present case,
the Auditor sought fees pursuant to 42 Pa. C.S.A. § 2503 as a sanction for the Brothers' "dilatory,
obdurate or vexatious conduct during the pendency of a matter" including the Brothers' pursuit of
the Petition for Administrator Pro Tem. The Brothers' filing exceptions to the denial of that
Petition, seeking an appeal of that denial, and requesting reconsideration of the quashing of the
appeal were all part and parcel of the Brothers' obdurate conduct in stubbornly pursuing, for over
15 months, the meritless Petition for Administrator Pro Tem. Those fees can be awarded by the
trial court as a sanction under § 2503. Therefore, the Auditor erred in refusing to award to the
Executor the fees he incurred during the appellate proceedings on the Petition for Administrator
Pro Tem.
Fourth Objection
Marshall objects to the Auditor's recommendation that the Estate be directed to pay the
fees of the auditor and the court reporter that were incurred in connection with the Executor's
Motion for Attorneys' Fees. That recommendation states as follows:
Finally, it is recommended that the Estate be directed to pay the fees of the auditor
and the court reporter for the same reasons as set forth in the auditor's report of
September 19, 201 1, with respect to the objections of the Brothers to the Estate
Account.
(Auditor's Report, p. 38).
The Auditor's recommendation that the Estate bear the Auditor's fees and Court Reporter's fees
that were incurred as a result of the Motion for Attorneys' Fees misapplies existing law and
makes a manifestly unreasonable judgment.
While the costs of the audit are usually borne by the fiduciary estate, in certain
circumstances, the costs can be shifted to another party. In re Estate of Vaughn, 461 A.2d 1318
(Pa. Super. 1983). The Estate should not bear the burden of increased expense resulting from the
motion that was necessary to sanction the Brothers for their inappropriate conduct during the
audit proceedings. The Motion for Attorneys' Fees was filed because of the Brothers' wrongful
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conduct. Absent that wrongful conduct, the Auditor's fees and Court Reporter's fees that were
incurred in addressing the Motion for Attorneys' Fees would not have been incurred. Therefore,
the Brothers should bear the Auditor and Court Reporter fees that were incurred in connection
with the Motion for Attorneys' Fees. Further, as noted at February 23 hearing, there are no assets
in the Estate to pay those fees, other than the real estate which was devised to the Executor and
Charlotte. (Transcript, p. 120). Therefore, to the extent that the Auditor has ordered his fees and
the Court Reporter's fees to be paid from the Estate, he has effectively imposed those costs upon
only Marshall and Charlotte, which result is entirely inequitable.
McNEES WALLACE & NURICK LLc
U
By . ,.V,,.,.~
Elizabeth P. Mullaugh
I.D. No. 76397
Kimberly M. Colonna
I.D. No. 80362
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
717- 232-8000
Counsel for Marshall Dixon as Executor of the
Estate of Lottie Ivy Dixon
Date: June 12, 2012
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the forgoing
documents were served by first class mail, postage prepaid, addressed as follows:
Walter W. Cohen, Esquire
Kevin J. Kehner, Esquire
Obermayer Rebmann Maxwell &Hippel LLP
200 Locust Street, Suite 400
Harrisburg, PA 17101
Paul C. Heintz, Esquire
Nina B. Stryker, Esquire
Erin E. McQuiggan, Esquire
Obermayer Rebmann Maxwell &Hippel LLP
One Penn Center, 19th Floor
1617 JFK Boulevard
Philadelphia, PA 19103
Mark Bradshaw, Esquire
Stevens & Lee, F.C:
17 N. Second St., 16th Floor
Harrisburg, PA 17101
Daniel L. Sullivan, Esq.
Saidis Sullivan & Rogers
26 West High Street
Carlisle, PA 17013
Wayne F. Shade, Esquire
53 W. Pomfret St.
Carlisle, PA 17013
Charlotte Ivy Dixon
323 Bayview Street
Camden, ME 04843
J
Kimberly . Colonna
Dated: June 12, 2012