Loading...
HomeMy WebLinkAbout73-0330INRE: ESTATE OF ERWIN C. OPPERMAN, DECEASED COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-73-330 PETITION FOR APPOINTMENT OF SUCCESSOR TRUSTEE IN ACCORDANCE WITH 20 PA. CONS. STAT..AI~.;~ {}7101. TO THE HONORABLE, THE JUDGES OF SAD COURT: The Petition of Bridget M. Whitley, respectfully represents that: Erwin C. Opperman (the "Decedent") died on May 19, 19~73 leav~ a Will:dated January 18, 1971 (the "Will"), probated in the office of the Register of Wills of Cumberland County, Pennsylvania on June 12, 1973, a copy of which is attached as Exhibit A, whereby he appointed Clarence E. Miller ("Miller") and William H. Wood ("Wood") as executors and trustees. 2. Miller and Wood filed a First and Final Account as Executors on October 18, 1974, together with a Proposed Schedule of Distribution. By Order dated November 26, 1974, the Account was confirmed absolutely and distribution decreed in accordance with the Proposed Schedule of Distribution. 3. The trust arises as follows: pursuant to Item IH of the Will, the Decedent's corporate securities were distributed to Miller and Wood, in trust for the benefit of the Decedent's cousin, Helen Opperman Krause ("Krause"). Krause was entitled to receive from the trust, for as long as she lived, all of the net income. Upon Krause's death, the Will directs that the trust terminate and the remaining principal and undistributed income be divided and distributed in equal shares to the Camp Hill Presbyterian Church, Camp Hill; the Market Square Presbyterian Church, Harrisburg; and the St. Michael's Evangelical Lutheran Church, Harrisburg. 4. Trustee Miller died onMarch 13, 1992. Trustee Wood died onMarch 2, 1999. Beneficiary Krause died on December 27, 1999. 5. The trust cannot be terminated unless and until a successor trustee is appointed to fill the complete vacancy in the office of trustee, as the Will does not name a successor or substitute trustee. 6. Pursuant to 20 Pa. Cons. Stat. Ann. §§ 722 and 723, the sims of the Trust is Cumberland County, Pennsylvania, and this Court has jurisdiction pursuant to 20 Pa. Cons. Stat. §711. 7. The names and addresses of all parties in interest, each of which is entitled to an equal share of the remainder, are as follows: Lloyd Persun, President Camp Hill Presbyterian Church c/o Mette Evans & Wooside P.O. Box 5950 Harrisburg, PA 17110-0950 Rev. James D. Brown Market Square Presbyterian Church 20 South 2nd Street Harrisburg, PA 17101-2040 Rev. Russell Mueller St. Michael's Evangelical Lutheran Church 118 State Street Harrisburg, PA 17101-1024 8. The consents of the parties in interest to this Petition are attached as Exhibit B. -2- 9. The Attorney General of the Commonwealth of Pennsylvania has reviewed a draft copy of this Petition, and has no objections to it, as evidenced by the letter attached as Exhibit C. 10. The principal of the trust consists of the following assets: 324 shares of Wachovia Corporation ~ $48.00 300 shares PPL Corporation ~ $48.00 Certificates of Deposit at M & T Bank Certificate of Deposit at Wachovia Bank Checking Account at M & T Bank $15,552.00 14,400.00 11,000.00 1,000.00 7,500.00 There may be additional assets in a safe deposit box, which cannot be determined until a successor trustee is appointed, and the box opened and inventoried. 11. The proposed Successor Trustee is Bridget M. Whitley, Esq., a Senior Attorney with the law firm of Keefer Wood Allen & Rahal, LLP (prior to his death, Trustee Wood was a partner of this finn), whose business address is 210 Walnut Street, Harrisburg, Pennsylvania, and whose consent to serve as successor Trustee is attached hereto as Exhibit D. The proposed Successor Trustee has no relationship to any party in interest, nor any interest in the trust. 12. The Will does not waive the posting of security by the trustee. WHEREFORE, Petitioner respectfully requests that this Court appoint Petitioner Bridget M. Whitley as Successor Trustee of the trust under Item III of the Will dated January 18, 1971, with such security as the Court shall require. Respectfully submitted, Date: Bridget M. Whitley -3- VERIFICATION The undersigned, Bridget M. Whitley, hereby verifies and states that the facts set forth in the foregoing petition are true and correct to the best of her knowledge, information, and belief; and that she is aware that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. §4904, relating to unswom falsification to authorities. . · Bridget M. Whitley~ -4- LAST WILL AND TESTAMENT OF ERWIN C. OPpERMAN I, ERWIN C. OPPERMAN, of Camp Hill, Cu~erland County, Pennsylvania, do hereby make, publish and declare this as and for my Last Will and Testament, hereby revoking any former Wills or Codicils made by me. ITEM I. I order and direct that all my just debts and funeral expenses be paid out of my estate by my Executors herein- after named, as soon as may conveniently be done after my death. ITEM II. I give and bequeath all my personal effects such as clothing, books, household goods, jewelry and automobile, (except bank account or accounts and securities or other intangible personal property) to my cousin, HELEN OPPEP~4AN KRAUSE, absolutely, if she survives me. ITEM III. I hereby give and bequeath all corporate securities which I may own at the time of my death to my :Trustees hereinafter named, in trust, nevertheless, to hold, man~ge,'.invest and reinvest the same, collect the income therefrom and dispose of the principal and net income therefrom as follows: (a) So long as my cousin, HELEN 0PpERMAN KRAUSE, is living, all of the net income from the Trust shall be paid to her or applied directly for her benefit, at such times and in such amounts as my Trustees, in their sole discretion, may deem advisable. witnesses: (b) Upon the death of my cousin, HELEN OPPERMAN KRAUSE, this Trust shall terminate and the principal and any undistributed income therefrom shall be divided into three equal shares, one of which shall be paid over absolutely to CAMP HILL pRESBYTERIAN CHURCH, Camp Hill, Pennsylvania; one to MARKET SQUARE PRESBYTERIAN CHURCH, Harrisburg, Pennsylvania; and one to ST. MICHAEL'S EVAN- GELICAL LUTHERAN CHURCH, Harrisburg, Pennsylvania. ITEM IV. Ail the rest, residue and remainder of my estate, of whatsoever nature and wheresoever situate, I give, de- vise and bequeath as follows: 1. My Executors shall arrange and pay for suitable markers for sny unmarked graves for members of my family in our family lot in Harrisburg Cemetery. 2. The remainder of my said residuary estate shall be divided into twelve (12) equal shares and distributed as follows: (a) One share to my cousin, HELEN OPPERMAN KRAUSE, if she is surviving at the time of my death. (b) One share to KARL T. OPPERMAN, JR.,' of Coilings- wood, New Jersey, or if he is not surviving at the'time of my d~ath, then to his children in equal shares. (c) One share to KARL T. OPPERMAN, III, of War- minster, Pennsylvania, or if he is not surviving at the time of my death, then to his children in equal shares. (d) One share to MISS SARAH H. MARTIN, Registered Nurse, of Middletown, Pennsylvania, if she is surviving at the time of my death. witnesses: (S~L) (e) One share to MRS. PEAR3~ A. BARRICK, Registered Nurse, R. D. 4,Mechanicsburg, Pennsylvania, if she is sur- viving at the time of my death. (f) One share to MRS. RAYMOND CHESTER WALKER, Ca~ Hill, Pennsylvania, if she is surviving at the time of my death. (g) One share to GETTYSBURG COLLEGE ALUMNI ASSOCIA- TION. (h) One share to'DAVID p. DHATRICH MEMORIAL BUILDING FUND of SIGMA ALPHA EPSILON FRATEP~NITY, GETTYSBURG COLLEGE, Gettysburg, Pennsylvania. (i) One share to the SALVATION ARMY, Harrisburg, Pennsylvania. (j) One share to the VOLUNTEERS OF AMERICA, Harris- burg, Pennsylvania. (k) One share to the AMERICAN LEPROSY MISSIONS, INC., 297 Park Avenue South, New York City. (1) One share to HARRISBURG CEMETERy A~SOCIATION, Harrisburg, Pennsylvania. If any person or persons to whom a legacy is provided for in subparagraphs (a), (d), (e) and (f) of this ITEM IV is or are not surviving at the time of my death, then the legacy or legacies due such person or persons shall be added lin equal portions to the remaining legacies provided for in this ITEM IV. ITEM V. I hereby nominate, constitute and appoint witnesses: (s~AL) PASTOR CLARENCE E. MILLER of Harrisburg, Pennsylvania, and WILLIAM H. WOOD of Lemoyne, Pennsylvania, as Executors of this my Last Will and Testament. I hereby nominate, constitute and appoint PASTOR CLARENCE E. MILLER and WILLIAM H. WOOD as Trustees of the Trust created under ITEM IV of this Will. ITEM VI. Ail estate, inheritance, legacy, succession or transfer taxes (including any interest and penalties thereon) imposed by any domestic or foreign laws now or hereafter in force with respect to all property taxable under such laws by reason of my death, whether or not such property passes under this my Will and whether such taxes be payable by my estate or by any recipient of any such property, shall be paid by my Executors, at'such time or times as may be deemed advisable, out of my general estate as part of the expenses of the administration thereof with no right of reimbursement from any recipient of any such property. ITEM VII. The principal of the aforesaid Trust and the income therefrom shall be free from the control, debts, liabilities and engagements of the beneficiaries and shall not be subject to assignments, liens, attachments, executions, sequestrations or claims of any sort whatsoever against her. ITEM VIII. I hereby authorize my Executors and Trustees to make partial or complete distribution to beneficiaries of my estate, from time to time, during the administration thereof; to witnesses: distribute unequal amounts to similar beneficiaries,' from time to time, during such administration and to make such other distribu- tions during administration as they may determine. Nothing con- tained in this Item shall be construed as authorizing my~Executors and Trustees to vary the dispositive provisions of this Will. ITEM IX. The Trustees shall not be responsible for, liable for, or charged with, any loss or depreciation that may arise in connection with the trust estate, Or in connection with any other securities and real estate purchased by it forming any part of the trust estate, it being expressly understood that the Trustees shall be liable for gross negligenoe only. ITEM X. I hereby e~ressly authorize and empower my Executors and my Trustees of the Trust herein created, in their sole and absolute discretion: (a) To purchase or otherwise acquire, and to re~tain, whether originally a part of my estate or subsequently acquired, any and all stock, bonds, notes or other securities, .or: any variety of real or personal property, including stocks or interest in investment trusts and common trust funds, as they may deem advisable, whether or not such investments be of such character as to constitute legal investments by fiduciaries. (b) To sell, lease, pledge, mortgage, transfer, ex- change, convert or otherwise dispose of, or grant options with respect to, any and all property at any time forming a part of my Witnesses: --5-- 9EO estate or of the trust estate, in such manner, at such time or times, for such purposes, for such prices and upon such terms, credits and conditions as they may deem advisable. Any lease made by the Executors or by the Trustees may extend beyond th~ period fixed by statute for leases made by fiduciaries and beyond the duration of the Trust. (c) To borrow such sums of money as may be required for the purposes of administering my estate or the trust estate, from my Executors or Trustees, as individuals or as fiduciaries under any other trust agreement, or from such other persons as they may desire and to secure the ioan by a pledge of all or any part of the trust property, or mortgage, and to execute an accompanying bond authorizing the confession of judgment, and plain or collateral notes, or other evidences of indebtedness. Persons or corporations advancing money to the Executors or to the Trustees need not in- quire into the necessity, expediency or propriety of such ~ loan, nor see to the application of the money advanced. (d) To vote in person or by general or limited proxy with respect to any shares of stock or other securities held by them; to consent, directly or through a cormmittee or other agent, to the reorganization, consolidation, merger, dissolution or liquidation of any corporation in which my estate or the trust estate may have any interest, or to the sale, lease, pledge or mortgage of any property by or to any such corporation; and to make any payments and to take any steps which they may deem necessary or proper to enable them to obtain the benefit of any such transaction. Witnesses: (SEAL) (e) To hold investments in the name of a nominee. (f) TO complete, extend, modify or renew any loans, notes, bonds, mortgages, contracts or any other obligations which I may own or to which I may be a party or which may be ~iens or charges against any of my property or against my estate, although I may not be liable thereon, in such manner as they may deem ad- visable; to pay, compromise, compound, adjust, submit to arbitra- tion, sell or release any claims or demands of my estate or the trust estate as they may deem advisable, including the acceptance of deeds of real property in satisfaction of bonds and mortgages, and to make any payments in connection therewith which they may deem advisable. (g) TO make distribution of my estate or of the prin- cipal of the trust estate in kind and to cause any share to be composed of cash, property or undivided fractional shares in property different in kind from any other share. (h) To execute and deliver any and all instruments in writing which they may deem advisable to carry out any of the foregoing powers. No party to any such instrument in writing - ' signed by the Executors or by the Trustees shall be obliged to inquire into its validity, or be bound to see to the application by the Executors or Trustees of any money or other property paid or delivered to them pursuant to the terms of any such instrument. IN WITNESS WHEREOF, I, ERWIN C. OPPERMAN, the Testator, -7- 93Z (SEAL) have to this Last Will and Testament, written on eight (8) sheets of paper, sat my hand and seal this .-~ day of January, 1971. Signed, sealed, published and declared by the above- named ERWIN C. OPPERMAN, as and for his Last Will and Testament in the presence of us who have hereunto subscribed our names at his request as witnesses thereto, in the presence of the said Testator and of each other. Erwin C. Op~e~man , (SEAL) -8- '-" 933 CONSENT AND JOINDER TO PETITION FOR APPOINTMENT OF SUCCESSOR TRUSTEE IN ACCORDANCE WITH 20 PA. CONS. STAT. ANN. §7101 The undersigned, Rev. Russell Mueller, does hereby consent to and join in the Petition for Appointment of Successor Trustee. ~.,.,¢.o ~/ ~ RF~. RUS/SELL MUELLER COMMONWEALTH OF PENNSYLVANIA '~[.~ ss. COUNTY OF , I certify that on the ~ day of ~40 ~ ~ ,2004, REV. RUSSELL MUELLER personally appeared before me, a Notary Public of the Commonwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instrument. In witness whereof, I set my hand and office/ / /~/~,~ Notary Public COMMONWEALTH O1: PENNSYLVANIA INOTARIAL SEAL ' [PAMELA S WOLFE Notary Public ~C~ty of Harnsburg, Dauphin County ~ M)~ Commission Expires December 22,200~ CONSENT AND JOINDER TO PETITION FOR APPOINTMENT OF SUCCESSOR TRUSTEE IN ACCORDANCE WITH 20 PA. CONS. STAT. ANN. §7101 The undersigned, Lloyd Persun, on behalf of the Camp Hill Presbyterian Church, does hereby consent to and join in the Petition for Appointment of Successor Trustee. LLOYD PERSUN COMMONWEALTH OF PENNSYLVANIA SS. cOt T¥Or I certify that on the [~ day of Oc~ ,2004, LLOYD PERSUN personally appeared before me, a Notary Public of the Conmmnwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instrument. In wimess whereof, I set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Not,aria Seal Joan E. Brothers, Notary Public I Susquehanna Twp., Dauphin County [ [Myeommission Expires F~b. 12, 2006 I Member, Pennsylvania Association of Notaries CONSENT AND JOINDER TO PETITION FOR APPOINTMENT OF SUCCESSOR TRUSTEE IN ACCORDANCE WITH 20 PA. CONS. STAT. ANN. §7101 The undersigned, Rev. James D. Brown, on behalf of the Market Square Presbyterian Church, does hereby consent to and join in the Petition for Appointment of Successor Trustee. REV. ~ES D. BROWN COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ SS. I certify that on the _dayof .lllrD ~_ ~ _~_fl_fll ,2004, REV. JAMESD. BROWN personally appeared before me, a Notary Public of the Commonwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instrument. In witness whereof, I set my hand and official seal. Gerald J. Pappert Attorney General COMMONWEALTH OF PENNSYLVANIA OFFICE OF ATTORNEY GENERAL October 18, 2004 Charitable Trusts and Organizations Section 14th Floor, Strawberry Sq. Harrisburg, PA 17120 Telephone: (717) 783-2853 Facsimile: (717) 787-1190 Bridget M. Whitley, Esquire KEEFER, WOOD, ALLEN & RAHAL, LLP 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 Re: Trust Under the Will of Erwin C. Opperman Dear Ms. Whitley: This will acknowledge receipt of your notice pursuant to Supreme Court Orphans' Court Rule 5.5, regarding the above-captioned matter. Based upon the documents provided, I have no objection to the Prayer of the Petition. Please forward a copy of the filed Petition to my attention at the above address so that we may complete our file. In addition, we will need to review the Account and/or Receipt and Release Agreement when completed. Please be advised that the above review was conducted pursuant to the parens patriae function of this Office and has no bearing on any matter unrelated to that function. Thank you for your cooperation during the course of our review. Very truly yours, Heather J. Vance-Rittman Deputy Attorney General EXHIBIT D ACCEPTANCE OF OFFICE OF TRUSTEE Effective upon the issuance of the Order Appointing a Successor Trustee by the Orphans' Court Division of the Court of Common Pleas of Cumberland County, Pennsylvania, I, Bridget M. Whitley, accept the office of Trustee of the trust created under Item II~ of the Last Will and Testament of Erwin C. Opperman dated January 18, 1971. CERTIFICATE OF SERVICE I, Bridget M. Whitley, Petitioner, hereby certify that I have served the foregoing Petition upon the following parties of interest by depositing true and correct copies of the same in the United States mail, first-class postage prepaid, addressed as follows: Lloyd Persun, President Camp Hill Presbyterian Church c/o Mette Evans & Wooside P.O. Box 5950 Harrisburg, PA 17110-0950 Rev. James D. Brown Market Square Presbyterian Church 20 South 2nd Street Harrisburg, PA 17101-2040 Rev. Russell Mueller St. Michael's Evangelical Lutheran Church 118 State Street Harrisburg, PA 17101-1024 I further certify that on OCTOBER 12, 2004, I gave notice of the filing of the foregoing petition to the Attorney General of the Commonwealth of Pennsylvania by depositing a true and correct Copy of the same in the United States mail, certified mail, return receipt requested, addressed to: Gerald J. Pappert Attorney General for the Commonwealth of Pennsylvania Attention: Charitable Trusts and Organizations Section 14th Floor - Strawberry Square Harrisburg, PA 17120 Keefer, Wood, Allen & Rahal, LLP Dated: Bridget M. Whitley, Esq. S. Ct. No. 33580 210 Walnut Street Harrisburg, PA 17101 1N RE: ESTATE OF ERWIN C. OPPERMAN, DECEASED COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-73-330 ORDER APPOINTING SUCCESSOR TRUSTEE IN ACCORDANCE WITH 20 PA. CONS. STAT. ANN. {}7101 AND NOW, this day of -> ~ ~,./ ,~ / ,2004, upon consideration of her Petition, BRIDGET M. WHITLEY is appointed as successor Trustee for the trust under Item III of the Last Will and Testament ofErwin C. Opperman dated January 18, 1971. The requirement for the entry of security is waived. By the Court: / r ESTATE OF ERW1N C. OPPERMAN, DECEASED COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DWISION NO. 21-73-330 RECEIPT, RELEASE, REFUNDING AND INDEMNIFICATION AGREEMENT CONCERNING FINAL DISTRIBUTION OF TRUST THIS AGREEMENT, madethis ~O'~b~ dayof ~)~ ,2004 WITNESSETH: THE CIRCUMSTANCES leading up to the execution of this Agreement are as follows: 1. Erwin C. Opperman (the "Decedent") died on May 19, 1973, leaving a Will dated January 18, 1971 (the "Will"), probated in the office of the Register of Wills of Cumberland County, Pennsylvania on June 12, 1973, whereby he appointed Clarence E. Mdle dler")_~md William H. Wood ("Wood") as executors and trustees .... 2. Miller and Wood filed a First and Final Account as Executors on 1974, together with a Proposed Schedule of Distribution. By Order dated Noven'i~i"~6, 19~ the Account was confirmed absolutely and distribution decreed in accordance with the Proposed Schedule of Distribution. 3. The trust arises as follows: pursuant to Item 1/I of the Will, the Decedent's corporate securities were distributed to Miller and Wood, in trust for the benefit of the Decedent's cousin, Helen Opperman Krause ("Krause"). Kranse was entitled to receive from the trust, for as long as she lived, all of the net income. Upon Krause's death, the Will directs that the trust terminate and the remaining principal and undistributed income be divided and distributed in equal shares to the Camp Hill Presbyterian Church, Camp Hill; the Market Square Presbyterian Church, Harrisburg; and the St. Michael's Evangelical Lutheran Church, Harrisburg (the foregoing churches will hereinafter be referred to as the "Remainder Beneficiaries"). 4. Trustee Miller died on March 13, 1992. Trustee Wood died on March 2, 1999. Beneficiary Krause died on December 27, 1999. 5. By Order dated October 25, 2004, Bridget M. Whitley was appointed as Successor Trustee to fill the vacancy created by the death of Trustees Miller and Wood. 6. The Trust may now be terminated, and it is the desire of the Remainder Beneficiaries that the termination of the Trust be done without the formality of an accounting in a court of competent jurisdiction. 7. In consideration of the indemnifications and such other terms that are hereinafter provided, the Trustee is willing to terminate the Trust by agreement. 8. The Office of the Attomey General, Charitable Trusts and Organizations Section, has no objection to terminating the trust with an informal accounting and receipt and release agreement of the beneficiaries, as indicated by the letter appearing as Exhibit A. NOW THEREFORE, in consideration of the foregoing and intending to be legally bound hereby, the Remainder Beneficiaries, jointly and severally, for themselves, their successors and assigns, do hereby agree as follows: A. Waiver and Statement of Accounts. The Remainder Beneficiaries acknowledge receipt of the Trustee's informal account, which is attached hereto as Exhibit B, and declare that they have had the opportunity to review the account and based upon an examination (or on their decision not to make such an examination), they are satisfied that they have sufficient information to make an informed waiver of their right to a formal accounting for the trust administration, and do hereby waive the filing and auditing of same. -2- Approval of Termination. The Remainder Beneficiaries approve the termination of the Trust. Receipt of Assets. The Remainder Beneficiaries acknowledge receipt of the assets shown in on Exhibit B. Releases. The Remainder Beneficiaries, for themselves, their successors and as- signs, hereby absolutely and irrevocably remise, release, quitclaim and forever discharge the Trustee (in her capacity as a fiduciary and in her individual capacity) and each and every one of the Trustee's employees, agents, attorneys, advisors, and counselors, and their respective heirs, personal representatives, successors and assigns, of and from any and all actions, payments, accounts, reckonings, liabili- ties, claims and demands relating in any way to the Trustee's administration of the Trust, including but not limited to the failure of the Trustee to file an account of such administration with, and obtain the approval of, a court of competent jurisdiction, and the termination of the Trust as provided herein. Refunds. Each of the Remainder Beneficiaries, to the extent of the funds and/or assets received by it hereunder, covenants and agrees to refund upon demand by the Trustee all or any amount which may hereafter be determined by the Trustee or by a court of competent jurisdiction to have been an erroneous or excess distri- bution to it regardless of the cause of such erroneous distribution, and agree that any period for the limitation of actions for the collection of any erroneous distribution to it shall commence only at such time as the Trustee shall have obtained actual knowledge of such erroneous distribution and that in no event shall the period for the collection of any erroneous distribution be less than two years after the actual discovery thereof by the Trustee. Indemnifications. The Remainder Beneficiaries agree to indemnify and hold harmless the Trustee from and against any and all claims, loss, liability or damage which they may suffer or to which it may be subjected by reason of her administration of the Trust, the distribution of the Trust based on the informal accounting and not a formal accounting, and the distribution of the assets of the Trust without having the approval of a court of competent jurisdiction. The Trustee shall not be indemnified nor held harmless for any act or omission which would constitute a breach of her fiduciary duty, a violation of law, or act of bad faith or gross negligence. Voluntary Act. The Remainder Beneficiaries agree that this Agreement has been freely and voluntarily executed, and that they have not relied on any special inducement, promise, or representation other than those representations set forth herein. -3- Right to Counsel. The Remainder Beneficiaries acknowledge that they understand all of the terms and conditions of this Agreement, and that they have been advised by legal counsel for the Trustee that it may be in their best interest to seek the advice of independent legal counsel before executing this Agreement, in order to fully understand the legal consequences of such terms and conditions. Waiver ofPa. R.C.P. 229.1. The Remainder Beneficiaries agree to waive the provisions of Pennsylvania Rules of Civil Procedure Rule 229.1 (relating to sanctions for failure to receive settlement funds within twenty days after receipt of an executed release). Consent to Jurisdiction. The Remainder Beneficiaries consent to the Court of Common Pleas of Cumberland County, Pennsylvania, exercising personal jurisdiction over them in any suit or action ar/sing out of the enforcement of this Agreement. Governing Law. This Agreement shall be governed by the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the Remainder Beneficiaries have set their hands and seals on the attached Consents as of the date first above written. -4- CONSENT TO RECEIPT, RECEIPT, REFUNDING AND INDEMNIFICATION AGREEMENT THE UNDERSIGNED, Lloyd Persun, does hereby acknowledge receipt of the distribution made to the Camp Hill Presbyterian Church by the Trustee, and consents to the Receipt, Release, Refunding and Indemnification Agreement Concerning Final Distribution of Trust. LL/~fI) PERSUN COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF ~ I certify that on the ~ day of ~ ,2004, LLOYD PERSUN personally appeared before me, a Notary Public of the Commonwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instrument. (sEnti) In witness whereof, I set my hand and official seal. Not~a/y Public ~0MMONWF~ALTH OF p£NNSYLVANIA~ Notarial Seal . Joan E. Brothers, Notary. Public Susquehanna Tw~., .Dau~m.n Co ~ml,~[ ~MyCommission t:xpll~S I~eb. 12, Member, Pennsyl~18 Association of Notaries -5- CONSENT TO RECEIPT, RECEIPT, REFUNDING AND INDEMNIFICATION AGREEMENT THE UNDERSIGNED, Rev. Russell Mueller, does hereby acknowledge receipt of the distribution made to St. Michael's Evangelical Lutheran Church by the Trustee, and on its behalf consents to the Receipt, Release, Refunding and Indemnification Agreement Concerning Final Distribution of Trust. R~V. RUSSELL MUEILLER (SEAJ ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ce i y that on the qay of SS. ,2004,REV. RUSSELL MUELLER personally appeared before me, a Notary Public of the Commonwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instrument. In wimess whereof, I set my hand and official seal Notary Public ~ NOTARIAL SEAL I PAMELA S WOLFE Nolary Public / Qt¥ of Harrisburg Dauph n County I My Commission Expires December 22, 2007~ -6- CONSENT TO RECEIPT, RECEIPT, REFUNDING AND INDEMNIFICATION AGREEMENT THE UNDERSIGNED, Rev. James D. Brown, does hereby acknowledge receipt of the distribution made to Market Square Presbyterian Church by the Trustee, and on its behalf does hereby consents to the Receipt, Release, Refunding and Indemnification Agreement Concerning Final Distribution of Trust. (sEe) ~V J~IES D. BROX~ COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF ~ I certify that on the ~ fi~day of /~ ~'~'l., 2004, REV. JAMES D. BROWN personally appeared before me, a Notary Public of the Commonwealth of Pennsylvania, and acknowledged, to my satisfaction, that he is the person who executed the above instrument as his voluntary act and deed for the uses and purposes expressed in the instmment. In witness whereof, I set my hand and official seal. Notary Public -7- COMMONWEALTH OF PENNSYLVANIA OFFICE OF ATTORNEY GENERAL December 3, 2004 Gerald J. Pappert Attorney General Charitable Trusts and Organizations Section 14th Floor, Strawberry Sq. Harrisburg, PA 17120 Telephone: (717) 783-2853 Facsimile: (717) 787-1190 VIA FACSIMILE # (717) 255-8003 AND U.S. MAIL Bridget M. Whitley, Esquire KEEFER, WOOD, ALLEN & RAHAL, LLP 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 Re: Estate of Erwin C. Opperman Dear Ms. Whitley: This will acknowledge receipt of your notice pursuant to Supreme Court Orphans' Court Rule 5.5, regarding the above-captioned matter. Based upon the documents provided, I have no objection to the First and Final Account. Please be advised that the above review was conducted pursuant to the parens patriae function of this Office and has no beating on any matter unrelated to that function. Please forward copies of the signed Releases, when obtained, so that we may complete our file. Thank you for your cooperation during the course of our review. Very truly yours, Heather J. Vance-Rittman Deputy Attorney General EXHIBIT A COURT OF COMMON PLEAS OF CUMBERLAND, PA ORPHANS' COURT DIVISION FIRST AND FINAL ACCOUNTING OF Bridget M. Whitley, Trustee For Trust U/W Erwin C. Opperman Start of Trust: Date of Appointment: Accounting for the Period: November 26, 1974 October 25, 2004 October 25, 2004 to December 06, 2004 Purpose of Account: The above fiduciary offers this account to acquaint interested parties with the transactions that have occurred during his/her administration. It is important that the account be carefully examined. Requests for additional information, or questions, or objections, can be discussed with: Bridget M. Whitley Keefer Wood Allen & Rahal, LLP 210 Walnut Street, Harrisburg, PA 17101 EXHIBIT B Trust U/W Erwin C. Oppennan Smmnary of Account Principal Receipts Net Gain on Sales or Other Dispositions Less Disbursements: Administrative Expenses Balance Before Distributions Less Distributions to Beneficiaries Principal Balance On Hand For Information: Investments Made Unpaid Expenses Unrealized Gains and Losses Income Receipts Net Gain on Sales or Other Dispositions Less Disbursements: Balance Before Distributions Less Distributions to Beneficiaries Income Balance on Hand For Information: Investments Made Unpaid Expenses Unrealized Gains and Losses Combined Balance on Hand Page 2 4 6 8 10 11 11 12 12 12 12 13 13 13 $ 5.60 $ 45,774.26 7,011.91 $ 52,786.17 5.60 $ 52,780.57 0.00 $ 52,780.57 $ 17.07 0.00 $ 17.07 0.00 $ 17.07 0.00 $ 17.07 $ 52,797.64 Page 1 (1) Trust U/W Erwin C. Opperman Receipts of Principal FACE 3,000 3,000 3,000 1,987.55 1 000 No. of Shares 300 Cash and Cash Equivalents M & T Bank CD 31003914346445 Interest to Start of Trust M & T Bank CD 31003914375976 Interest to Start of Trust M & T Bank CD 3]0039]4376396 Interest to Start of Trust M & T Bank CD 31003914376487 Interest to Start of Trust M & T Bank Checking Account No. 65338049 Account No. 247411235245141 Total Cash and Cash Equivalents Stocks PPL Electric Utilties Total Stocks Miscellaneous Unclaimed Property Claim Proceeds of sale of 324 shares of Wachovia Bank, N.A. stock and uncollected dividends of $2,792.88 which were escheated Inventory Value 10/25/2004 3.000.00 5.36 3,000.00 3.99 3,000.00 3.10 1,987.55 0.80 7,679.27 1,000.00 6.03 $ Inventory Value 10/25/2004 8,809.79 Inventory Value 10125/2004 19,686.10 8,809.79 17,278.37 Page 1 (2) Receipts of Principal (Continued) Miscellaneous to the Commonwealth of Penna. Total Miscellaneous Total INVENTORY RECEIPTS SUBSEQUENT TO INVENTORY 11/01/2004 M & T Bank Trust Bank Acct No. 9836557281 Total RECEIPTS SUBSEQUENT TO INVENTORY Total Receipts of Principal Inventory Value 10/25/2004 $ 17,278.37 $ 45,774.26 0.00 0.00 $ 45,774.26 Page 2 (3) Trust U/W Erwin C. Opperman Gains and Losses on Sales or Other Dispositions of Principal Net Gain 11/01/2004 Redemption 3,000 Par H & T Bank CD 31003914346445 Net Proceeds $ Carried at 3,005.36 3,005.36 11/01/2004 Redemption 3, 000 Par H & T Bank CD 31003914375976 Net Proceeds $ Carried at 3,003.99 3,003.99 11/01/2004 Redemption 3,000 Par H & T Bank CD 31003914376396 Net Proceeds $ Carried at 3,003.10 3,003.10 11/01/2004 Redemption 1.987.55 Par M & T Bank CD 31003914376487 Net Proceeds $ Carried at 1,988.35 1,988.35 11/01/2004 Redemption Pass Thru Account ReQemption ot inEerest on Wachovia Bank CD Net Proceeds $ Carried at 0.43 0.43 11/01/2004 Redemption 1,000 Par Wachovia Bank CD Account No. 247411235245141 Net Proceeds Carried at 1,000.00 1,000.00 11/10/2004 Sale 300 Shares PPL Electric Utilties Net Proceeds $ Inventoried at 15,821.70 8,809.79 7,011.91 Net Loss Page 1 (4) Gains and Losses on Sales or Other Dispositions of Principal (Continued) Net Gain Net Loss 12/03D004 Colle~ion Unclaimed Property Claim Proceeds of sale of 324 shares of Wachovia Bank, N.A. stock and uncollected dividends of $2,792.88 which were escheated to the Commonwealth of Penna. Net Proceeds $ Carried at 17,278.37 17,278.37 Total Gains and Losses Net Gain $ 7,011.91 $ 7,011.91 $ 0.00 Page 2 (5) Trust U/W Erwin C. Opperman Disbursements of Pnncipal Date Paid 10/29/2004 Administration Expenses Wachovia Bank Penalty for early withdrawal Total Wachovia Bank Total Administration Expenses Total Disbursements of Principal Amount Paid $ 5.60 $ 5.60 $ 5.60 $ s.60 Page 1 (6) Trust U/W Erwin C. Opperman Principal Balance On Hand Valued as of December 06, 2004 Fair Market Value 12/06/2004 Inventory Value Cash and Cash Equivalents M & T Bank Trust Bank Acct No. 9836557281 $ 52.780.57 $ 52,780.57 $ 52,780.57 $ 52,780.57 $ 52,780.57 $ 52,780.57 Total Cash and Cash Equivalents Total Balance on Hand Page 1 (7) Trust U/W Erwin C. Opperman Information Schedules - Principal New Investments M & T Bank CD 31003914346445 11/01/2004 M & T Bank CD 31003914375976 11/01/2004 M & T Bank CD 31003914376396 11/01/2004 M & T Bank CD 31003914376487 11/01/2004 Total New Investments Exchanges and Stock Distributions M & T Bank CD 31003914346445 10/25/2004 3,000 Par 11/01/2004 11/01/2004 (3,000) Par M & T Bank CD 31003914375976 10/25/2004 3,000 Par 11/01/2004 11/01/2004 (3,000) Par M & T Bank CD 31003914376396 10/25/2004 3,000 Par 11/01/2004 11/01/2004 (3,000) Par Purchased via Reinvestment Purchased via Reinvestment Purchased via Reinvestment Purchased via Reinvestment Received Income Reinvestment Redeemed Received Income Reinvestment Redeemed Received Income Reinvestment Redeemed In~egtory value $ 5.36 $ 3.99 $ 3.10 $ 0.80 '13.25 Inventory Value 3,000.00 5.36 (3,005.36) $ 3,000.00 3.99 (3,003.99) $ 3,000.00 3.10 (3,003. I 0) Page 1 (8) Information Schedules - Principal (Continued) Exchanges and Stock Distributions M & T Bank CD 31003914376487 10/25/2004 1,987.55 Par 11/01/2004 11/01/2004 (1,987.55) Par PPL Electric Utilties 10/25/2004 300 Shs. 11/10/2004 (300) Shs. Umclaimed ProDertv Claim Proceeds of sale of 324 shares of Wachovia Bank, N.A. stock and uncollected dividends of $2,792.88 which were escheated to the Commonwealth of Penna. 10/25/2004 12/03/2004 Wachovia Bank CD Account No. 247411235245141 10/25/2004 1,000 Par 11/01/2004 (1,000) Par Received Income Reinvestment Redeemed Starting Balance Sold Received Collected Received Redeemed Inventory Value $ 1,987.55 0.80 (1,988.35) $ 8,809.79 (8,809.79) $ 17,278.37 (17,278.37) $ 1,000.00 (1,000.00 Page 2 (9) Trust U/W Erwin C. Opperman Unpaid Principal Expenses Administration Expenses Bridget M. Whitley Trustee commission and attorney fees and disbursements (including reserve for tax return preparation) Total Bridget M. Whitley Total Administration Expenses Total Unpaid Expenses $ 6,000.01 $ 6~000.01 $ 6,000.01 $ 6,000.01 Page 1 (10) Trust U/W Erwin C. Opperman Receipts of lncome Income Collected M & T Bank CD 31003914346445 11/01/2004 Interest on 3,000 Par Less accrued portion 11/01/2004 Interest on 3,000 Par M & T Bank CD 31003914375976 11/01/2004 Interest on 3,000 Par Less accrued portion 11/01/2004 Interest on 3,000 Par M & T Bank CD 31003914376396 11/01/2004 Interest on 3,000 Par Less accrued portion 11/01/2004 Interest on 3,000 Par M & T Bank CD 31003914376487 1]/01/2004 interest on 1,987.55 Par Less accrued portion 11/01/2004 Interest on 1,987.55 Par Wachovia Bank CD Account No. 247411235245141 10/29/2004 Interest on 1,000 Par Less accrued portion Total Income Received $ 5.36 (5.36) 1.42 $ 3.99 (3.99) 1.06 $ 3.10 (3.i0) i.3i $ 0.80 (0.80) 13.28 $ 6.03 (6.03) $ 1.42 1.06 1.31 13.28 0.00 17.07 Page 1 (11) Trust U/W Erwin C. Opperman Income Balance On Hand Valued as of December 06, 2004 Fair Market Value 12/06/2004 Cash and Cash Equivalents M & T Bank Trust Bank Acct No. 9836557281 Inventory Value Total Cash and Cash Equivalents Total Balance on Hand $ 17.07 $ 17.07 $ t7.07 $ 17.07 $ 17.07 $ 17.07 Page 1 (12) PROPOSED SCHEDULE OF DISTRIBUTION Cash on hand for distribution To: Keefer Wood Allen & Rahal For services of Bridget M Whitley as trustee and attorney To: Camp Hill Presbyterian Church One-third of remainder To: Market Square Presbyterian Church One-third of remainder To: St. Michael's Evangelical Lutheran Church One-third of remainder Total $52,797.64 6,000.01 15,599.21 15,599.21 15,599.21 $52,797.64 EXHIBIT C