HomeMy WebLinkAbout04-30-13 John B. Zonarich,Esquire
Email: jbz @skarlatoszonarich.com
Identification No. 79989
Elizabeth B.Place,Esquire o rn C->Email: ebp @skarlatoszonarich.com W 2 (:>
Identification No. 44682 M _ C->
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D w rya rn
Skarlatos Zonarich LLC n m M o , v
Skarlatos& Zonarich Building o � ° -°„
17 South Second Street, 6th Floor o °c
Harrisburg, Pennsylvania 17101 X M
Telephone (717) 233 - 1000
Attorneys for Petitioner, Gloria J. Banks, Guardian of c a
Inez H. Davis, an Incapacitated Person
COURT OF COMMON PLEAS
ESTATE OF INEZ H. DAVIS, CUMBERLAND COUNTY,
An Incapacitated Person. PENNSYLVANIA
ORPHANS' COURT DIVISION
O.C. NO. 21-07-0200
SUPPLEMENTAL PETITION FOR ALLOWANCE OF
DISTRIBUTION OF PRINCIPAL OF AN INCAPACITATED PERSON
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
The Petition of Inez H. Davis, an Incapacitated Person, by her daughter and guardian,
Gloria J. Banks, by and through her counsel, SkarlatosZonarich LLC, respectfully requests:
1. Petitioner is Gloria J. Banks, an adult individual who resides at 5776 Catherine
St., Harrisburg, PA 17112; Petitioner is the daughter and the plenary guardian of the estate and
person of her mother, Inez H. Davis.
I. BACKGROUND
2. On January 15, 2013, Petitioner filed a Petition for Allowance of Distribution of
Principal of an Incapacitated Person; subsequent to an April 10, 2013 hearing on the Petition, the
Y
Court asked Petitioner to submit"a new proposed decree and any information pertaining thereto
as to how there may be assets left in the estate of the incapacitated person such that the State may
then recover some of these assets for payment of her stay at the Jewish Home and any nursing
home after the incapacitated person is deceased."
3. Upon the death of a Medical Assistance recipient,any assets in the recipient's
probate estate are subject to Pennsylvania's Medical Assistance Estate Recovery and are applied
to repay the State for Medical Assistance(MA)benefits paid on the recipient's behalf;the only
estate assets a current MA recipient could have would be those that are "excluded" in
determining eligibility, typically limited to a home,vehicle or any amounts remaining of the
recipient's resource set-aside(up to $8,000.00 in the instant matter). 42 P.S. §1412, 55 Pa. Code
ch. 258.
IL HANDICAP ACCESSIBLE VEHICLE
4. The averments of the January 15,2013,Petition for Distribution are incorporated
herein by reference.
5. The cornerstone of the plan for optimizing the Incapacitated Person's quality of
life is the purchase of an accessible vehicle which will allow her to participate most fully in the
life of her family and engage in the world outside the nursing home.
6. Any interest the Incapacitated Person has in a vehicle, assuming it is not subject
to a survivorship interest, is subject to Medical Assistance Estate Recovery(MAER).
7. An incapacitated person is able to co-own, register and insure a vehicle in
Pennsylvania with a joint owner who is a licensed,insurable driver with valid Pennsylvania
identification.
8. Since the Court has directed Petitioner to create a MAER asset, Petitioner seeks
approval for the purchase of an accessible vehicle titled in the name of the Incapacitated Person
and Petitioner. as tenants in common;upon the Incapacitated Person's death,the Incapacitated
Person's one-half interest in the vehicle would be subject to Pennsylvania's MAER regulations.'
9. While Pennsylvania's public policy reflects a desire to recoup MA expenditures
through MAER, statutes allowing MA applicants to transfer assets to disabled children also
reflect public policy favoring parental assistance to those suffering from disabilities.
10. In the instant case, since the Incapacitated Person will not have sufficient assets
to maintain the vehicle over her life expectancy,joint ownership is especially equitable since
Petitioner, the Incapacitated Person's disabled daughter, will be bearing the operating expenses
of the vehicle for the benefit of the Incapacitated Person,
11. The ongoing operating costs include insurance, maintenance,repairs, registration,
inspection and gas over the eight year life expectancy of the Incapacitated Person.2
'The ownership of the accessible vehicle involves an initial significant expenditure of funds;the cost of the
accessibility conversion alone is in excess of$25,000. Attached hereto as Exhibit"A"is an estimate for a Chrysler
conversion van which is currently available for$60,371.20 and is believed to be the model to best accommodate the
Incapacitated Person's size and proposed wheelchair. Attached as Exhibit`B"is correspondence from Gregory L.
Seitz,Total Mobility Services,commenting on the fit of the Chrysler van for the Incapacitated Person.Per Exhibit
"T"to the Petition for Allowance of Distribution,the cost of an extended warranty is$1,035.00.
2 Motor Trend Magazine reports a five year cost of ownership for a 2013 Chrysler Town&Country Van as follows:
maintenance($1,901.00),repairs($530.00),fuel($12,727.00),insurance($6,490.00),and state fees($483.00),
totaling$20,537.00. Motor Trend Magazine report attached hereto as Exhibit"C". The likely fuel costs for the
Incapacitated Person would be lower than this report. However,the cost to operate the vehicle would extend beyond
the reported five years;the Incapacitated Person's life expectancy is in excess of eight years.Further,insurance
costs are higher for a conversion vehicle than for a standard vehicle. Attached hereto as Exhibit"D"is a Liberty
Mutual Insurance quote(including full replacement coverage to protect the State's MAER interest)of$1,776.00 per
year. In addition, maintenance for the van's conversion equipment is estimated at$500.00 annually over a 10 year
period. See attached statement from Gregory L.Seitz,Total Mobility Services,Exhibit"B". The purchase of a new
vehicle is being sought due to the 36 month/36,000 mile warranties that cover the vehicle and the conversion,as
well as expected lower operating cost.Petitioner also seeks to purchase an extended warranty as referenced in
footnote one(1)above and requests a year of insurance coverage from the Incapacitated Person's funds. In
shopping for a used vehicle,the somewhat lower purchase price does not appear to result in savings sufficient to
offset the potential for costly repairs.
12. In considering distributions of principal of an incapacitated person,the Court
substitutes its judgment for that of the incapacitated person considering the incapacitated
person's likely intent.
13. It is averred that the Incapacitated Person would choose to title the vehicle in
Petitioner's name alone, as well as transfer to her funds for operating the vehicle, in recognition
of Petitioner's constant care, advocacy and financial support of the Incapacitated Person despite
Petitioner's own struggles, and consistent with the Incapacitated Person's lifelong pattern of
generosity to her children. See Petition for Allowance of Distribution,paragraphs 59—76,
incorporated herein by reference.
14. It is averred that at a minimum, the Incapacitated Person would want her disabled,
financially challenged daughter to have a one-half ownership interest in the vehicle,which will
literally be a vehicle of j oy to the Incapacitated Person—made possible with Petitioner's on-
going financial support,
III. Legal Fees
15. Petitioner seeks permission to invade principal to pay for legal fees in the amount
of$5,248 for services rendered on the Incapacitated Person's behalf subsequent to those
submitted with the January 15,2013 Petition. Invoices for services,redacted as necessary for
confidentiality, are attached as Exhibits"E""I"'and"G".
16. Petitioner's consent is attached hereto as Exhibit"H".
WHEREFORE, Petitioner respectfully requests this Court authorize Petitioner to
distribute the Incapacitated Person's principal as described herein pursuant to the attached
proposed Order.
Respectfully submitted,
SKARLATOSZONARICH LLC
Dated: April3a, 2013
By:tJB �,,r _
Zonarich Esquire
ation No. 79989
Elizabeth B. Place
Identification No. 44682
Skarlatos & Zonarich Building
17 South Second Street, 6th Floor
Harrisburg, Pennsylvania 17101
Telephone (717) 233 — 1000
Facsimile: (717)233 —6740
Email.jbz@skarlatoszonarich.com
ebp@skarlatoszonarich.com
Attorneys for Petitioner
VERIFICATION
I, Gloria J. Banks, am the Petitioner in this action and hereby verify that the statements
made in the foregoing SUPPLEMENTAL PETITION FOR ALLOWANCE OF
DISTRIBUTION OF PRINCIPAL are true and correct to the best of my knowledge,
information and belief.
I understand that the statements in said Petition are made subject to the penalties of 18
Pa.C.S.A. §4904 relating to unworn falsification to authorities.
Dated:
Gloria J. B AeAJPeti t ioner
EXHIBIT A
3 locations to BETTER Estimate
serve you
7917 Derry 5t/Harrisburg, p3r' (' 4785 Penn.Ave. Estimate#
Boswell PA. 15531
Convenient Sales Vices, Showrooms, and service 814-629-9935
to Boswell, PA - Harrisburg, PA -Fredaricir MD 814-629-9937 Fax $ 4634
C harl ie@,tmservices.com
Ray @tmservices Date
7917 Derry St. Ste. l24
REV.GARY&GLORIA BANKS
Harrisburg, PA, 17111 4(29/2013
5776 CATHIRNE ST. 717-5584301
HARRISBURG PA 17112 717-558-4303 Fax
717-979-1390 Greg @unservices.corn
Todd trnservices.cotn *T
5415 Yukon Ct.Ste.E
Frederick,MD.21703
Ship To 240-490-7840
240-490-7843 Fax 4 �s
I:NAZ DAMS Sul @tmservices
Webslte -- Terms
www.tmservices.com
Item Description
Qty Total
TOWN&COUNTRY 2013 CHRYSLER TOURING-L VIN#2C4RCICG3DR711037
CRYSTAL BLUE PEARL COAT EXTERIOR LEATHER 1 35,520.00T
INTERIOR-SEE ATTCH FOR DETAILS
CONVF..RSION REBATES DISCOUNTS FROM MANUFACTURES-
CHRYSLER REBATES THRU 4/30/2013 1 -1,500.00
CONVERSION REBATES DISCOUNTS FROM MANUFACTURES-
CHRYSLER MID ATALANTIC BONUS TRHU 4/30/2013 1 -500.00
MISCTT TITLE AND TRANSFER
2011-13 NORTHSTA... 201 1-13 DODGE,NORTHSTAR 1 I "1N FLOOR RAMP SYSTEM 1 375.00
WITH SURE DEPLOY COLOR ORDINATE CARPETING 1 23,995.00
LOWERED FLOOR PROVIDING 55"DOOR OPENING.30.5"
DOOR OPENING WIDTH 29.75"RAMP WIDTH POWER.
KNEEING SYSTEM,INTERIOR HEIGHT APR.58"HIDDEN
SPARE 89.5"OVERALL FLOOR LENGTH,REMOVABLE
RUB FLOOR DRIVER&PASSENGER SEATS
RUBBER FLOORING
Q-8100-A-L-HBG Q-STRA.INT QRT 8IOOA-L SELF WRACHETING I 655.00
WHEELCHAIR OCCUPANT RESTRAINT SYSTEM W/LAP& 1 895.00
SHOULDER BELT
FREIGHT OUT TRANSPORT FROM PLAT TO PA
TMS DISCOUNT CO... DISCOUNTS FOR CONVERSIONS FROM TMS 1 ',300.00
CONVERSION CHRYSLER.MOBILITY PROGRAM 1 -1,500.00
1 -11000.00
ACCEPTANCE SIGNATURE
Subtotal
CHASIS PAYMENT DUE AT ACCEPTANCE&50%CONVERSION AMID BAL @ $58,240.00
COMPLETION Sales Tax (16.0%,)
$2,131.20
Total $60,371.2()
WINDOW STICKER
T' 2413 MODEL YEAR
CHRYSLER TOWN &
COUNTRY TOURING-L
RICE INFORMATION PRICE INFORMATION(contd.)
MANUFACTURER'S SUGGESTED RETAIL PRICE Of OPTIONAL EQUIPMENT
THIS MODEL INCLUDING DEALER PREPARATION
Cusmmer Preferred Package 29J
Base Price:$33,530 Light Graystone Seats
1tlt Front Easy Clean Floor Mats
CHRYSLER TOWN&COUNTRY TOURING-L Left Rear Easy Clean Floor Mats
Exterior Coior.Crystal Blue Pearl Coat Exterior Paint Right Rear Easy Clean Floor Mats
iriterlor Cotor.Black 1 Light Graystone interior Colors Uconnect(R)430N SATICDIDVD1MP31 $995
intertw:Leather-Trimmed Bucket Seats HDDli4AV
Engine:3.6-Liter V6 24-Valve VVT Engine Garmin(R)Navigation System
Transmission:6-Speed Automatic Transmission SidusXM Travel UnkllYr Travel Link
STANDARD EQUIPMENT(UNLESS REPLACED BY Subscription
Flex Fuel Vehicle
OPTIONAL EQUIPMENT) DESTINATION CHARGE$999
FUNCTIONALISAFETY FEATURES i
SafetyTec 7` TOTAL PRICE:*$35,520
Blind Spot and Cross Path Detection
ParkSense(R)Rear Park Assist System
Rain Sensitive Windshield Wipers
Automatic High Beam Headlemp Control
Tire Pressure Monitoring Sensor
ParkView(TM)Rear Back-Up Camera
Chrome Exterior Mirrors
Fuel Optimizer Calibration
Active Head Restraints
Advanced Multistage Front Airbags
Supplemental Side-Curtain Airbags in All Rows
Driver Inflatable Knee-Bolster Airbag
Supplemental Front Seat-Mounted Side Airbags
Electronic Stability Control
Security Alarm
Remote Start System
Keyless Entry with Immobilizer
Trailer Sway Damping
INTERIOR FEATURES
Single Screen DVD Player
Wireless Headphones(IR)
2ndl3rd-Raw Stow'n Go(R)w13rd-Row Tailgate Seats
Power Front Driver and Passenger Seats
Steering Wheel Mounted Audio Controls
Air Conditioning with 3-Zone Automatic Temp Control
Child Seat Anchor System-LATCH Ready
Dual Glove Boxes
Second and Third-Row Manual Window Shades
Removable Center Front Seat Console
Tilt!Telescoping Steering Column
Uconnect(R)430 CDIDVDIMP31HDD
40 GB Hard Drive with 28 GB Available
6.5-Inch Touch Screen Display
Second-Row Overhead 9-inch VGA Video Screen
High Definition Multimedia Interface
SiriusXM Satellite Radio w1 1-Yr Radio Subscription
For More information,Call 688-539-7474
EXTERIOR FEATURES
17-Inch x 6.54nch Aluminum Painted Wheels
P225165R17 SSW All Season Tires
Premium Fog Lamps
Left Power Sliding Door
Right Power Sliding Door
Power Liftgate
Stow N Place Roof Rack
Exterior Mirrors with Heating Element
As"M*PokffiT'at ar Ent y WINDSOR,ONTARIO,CANADA
VIN:2C4RCICG3DR71I037 L4-VON:1349
This window sucker may or may nok nretdt the actual'ka DES AND DEALER SUPPLIED AND INSTALLED OPTIONS AND
sticker on the vehicle itself.We reserve the right to make ACCESSORIES ARE NOT INCLUDED IN THIS PRICE.DISCOUNT.
EXHIBIT B
7o&t
HAVCO Division
Gloria Banks
5776 Catharine Street
Harrisburg Pa27l12
717-979'2013 4/29/2013
Gloria,
Regarding our meeting of 10/26/2013 concerning your Mother Inez Davis,Mark Nice of Central Medical
Equipment and myself had reviewed her in actual wheelchair that she would be using when transported
in Accessible Van.You had actually brought Inez out tu physically try accessing the proposed modified
van.
|have attached several photos fronn our assessment of your Mobility options for transporting her imthe
Invacar Solaro Wheelchair.The accompanying proposal reflects the modified Chrysler Town and country
that contains the%'M| Nor1hstor wheelchair in-floor ramp system.
As we had reviewed earlier today here at the office,the in-floor ramp conversion will allow for proper
�
clearance for Inez while positioned in the front passenger position or the middle location.This reduces
any intrusion of Ramp so that it does not come in contact with her when closed.Also this allows for easy .
access into the vehicle by care giver or additional passengers to attend to her needs.
VMI conversion carries a 3-year 36k mile warranty. In our experience as general ru/e, noointenonce
costs,over a 10 year life span at approx.$500.00 per year.The Chrysler van itself all comes with 3 year
36k mile warranty.
Please feel free t$contact Noe with any questions concerning the proposal.
Thank you,
Gregory L.Seitz
TMS
7pl7DE)r[y Street, SU�itel24 ~ Harrisburg F\A /7ll1
� .�
pMQA6=_�� 7l7-558-43(}} 717-558~4303 �
eD7(]il: tm(]bi!�fy'&�Ppn-iSwQOd5�not
EXHIBIT C
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2013 Chrysler Town &Country Touring-L Passenger Minivan Costs
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Interior
Warranty Fuel $2,402 $2,472 $2,543 $2,617 $2,693 $12,727
Safety
.Safety Features Depreciation $9,538 $3,439 $3,239 $2,904 $2,460 $21,580
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EXHIBIT D
Your Auto Insurance Quote i'�' "
ut�
� y
Date: 04/29/2013 INSURANCE
INSURANCE INFORMATION
Prepared For: Gloria Banks ACTION
Gary A Banks REQUIRED:
Mailing Address: 5776 Catherine St
Harrisburg PA 17112-2208 Please call me to
Purchase your policy.
EhJeanethBalderrama
Sales Representative,) Y,tPr�mtttnLt ttt8ttfeEtdor,ittr (frs,, DRC
J'' :..........
1-877-557-6515
jeaneth.balderrama@
Your quote includes exclusive group savings as a result of your affiliation with M&T Bank. . SimrtP ify ymutoal.com
our life.
Discounts and Benefits Save with EFT.
Ask about signing up for
Your discounts and benefits have been applied to our total policy Electronic Funds Transfer
Your P y premium. (EFT).SAVE on your auto
Device •Earl
Anti-Theft Sho premium,support the
Y pper •Preferred Payment Method environment and ensure
•New Move •New-to-Liberty Vehicle •Paperless Policy Discount
your monthly payment is
•Vehicle Safety always made on time.
Coverage Information
Coverage Selected Limits
VEH 1
2013
CHRY
TOWN
Bodily Injury 100/300
$111
Property Damage 100
$108
Uninsured Motorist Coverage 100/300
UIM $12
100/300 $30
Tort Type Limited Tor
$0
First Party Benefits 5000
$125
Extraordinary Medical Benefits No Cov
$0
Other Than Collision
Deductible $213
Veh 1 Full
Collision
Deductible $407
Veh 1 $100
Towing and Labor 50
$5
Transportation Expense 45/1350
$51
Better Car Replacement Yes
$71 See next page
Customizing 25000 $643 for more.
Premium Per Vehicle
$1,776
- -- _ Page 1 of 2
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Coverage provided and underwritten by LM General Insurance Company, Boston, MA.
This quote is valid until 05/09/2013.
The premium quoted is an estimate based on the information you provided on the date prepared.The premium
quoted may change based on additional information obtained during the purchase process and various
consumer reports and other information that is obtained,as permitted by law,in order to confirm the accuracy
of the Information you have provided.This is not a contract or binder of coverage.
Includes state sales tax and local surcharge where applicable.
Page 2 of 2
EXHIBIT E
SkarlatosZonarich LLC
17 S Second St, 6th Floor
Harrisburg Pennsylvania 17101
Telephone(717) 233-1000
Fax (717)233-6740
INVOICE SUMMARY
Inez Davis
c/o Gloria Banks February 8,2013
5776 Catherine Street File #: DAVIIN1202
Harrisburg,PA 17112 Inv #:
59129
Attention:
RE: Elder Law
TOTAL PROFESSIONAL FEES
TOTAL EXPENSES MADE TO YOUR ACCOUNT $1,737.50
TAXES $131.38
PAYMENTS AND CREDITS $0.00
TOTAL BILL AMOUNT FOR INVOICE# 59129 $0.00
PREVIOUS BALANCE $1,868.88
INTEREST ON OVERDUE BALANCE $21,986.15
$0.00
PLEASE PAY THIS AMOUNT(Please see attached invoice detail)
$23,855.03
A IM 2%PER MONTH REBILLING CHARGE WHICH IS AN ANNUAL RATE OF 18%WILL BE APPLIED AFTER 30 DAYS, FEDERAL LD#25-1839294
PLEASE INDICATE YOUR INVOICE NUMBER ON YOUR REMITTANCE
59129 - -
2
INVOICE DETAIL
tez Davis
o Gloria Banks
776 Catherine Street
arrisburg, PA 17112
ttention:
F: Elder Law
ATE DESCRIPTION HOURS RATE AMOUNT
n-14-13 EBP Email exchanges with Gloria;final review of 1.50 $275.00 $412.50
petition for distribution with Gloria;
additition of exhibit
n-15-13 EBP Email exchange with Gloria Banks;instruction 1.00 $275.00 $275.00
to staff;preparation of notice; conference with
ROW regarding Notice
JKD Review and revise petition;telephone 3.80 $125.00 $475.00
conversation with Gloria Banks regarding fax;
preparation of documents for filing
n-16-13 EBP Preparation of Certificates of Consent and 0.40 $275.00 $110.00
correspondence to family members
BWM NO CHARGE --Drop of letters for Petition at 0.20 $0.00 $0.00
ROW
n-18-13 EBP Telephone call with Gloria Banks regarding 0.50 $275.00 $137.50
consent and tax issue;conference with Jackie
Wolpert regarding tax issues;email to Gloria
JBW IRS Notice-discuss with E Place and prepare 0.30 $200.00 $60.00
farm 2848 to prepare IRS response.
1-22-13 EBP Conference with Jackie Wolpert regarding tax 0.30 $275.00 $82.50
return
-29-13 EBP Review of consents;instructions to Toya 0.20 $275.00 $55.00
regarding notarization and correspondence to
Michael
JKD Correspondence to Michael Anthony Davis 0.40 $125.00 $50.00
regarding Certificate of Consent document to
be notarized
30-13 JKD Correpondence to Gloria Banks regarding copy 0.20 $125.00 $25.00
of Order of Court;scan and save to file{NC.2}
31-13 EBP Telephone call with Gloria regarding consents 0.20 $275.00 $55.00
and Order regarding objections
59129
Professional Fees 3
XPENSES: $1,737.50
Postage
$131.38
Total Expenses
Total Taxes Charged $131.38
$0.00
Total due this invoice
Previous Balance $1,868.88
$21,986.15
Payments received on previous balance
Interest due on overdue balance $0.00
$0.00
Please Pay This Amount
$23,855.03
11/29/*PER MONTH REB/LL/NC LD.#25-1839294 CHARGE WH/CH IS AN gNNUAL RATE OF 18%WILL BE APPL/Ep AFTER 30 DAYS.
?DERAL
I V//N1202
EXHIBIT F
SkarlatosZonarich LLC
17 ftecond St, 6th Floor
Harrisburg Pennsylvania 17101
Telephone(717)233-1000
Fax(717)233-6740
INVOICE SUMMARY
Inez Davis April 10, 2013
c/o Gloria Banks File#: DAVIIN1202
5776 Catherine Street Inv #: 59459
Harrisburg, PA 17112
Attention:
RE: Elder Law
TOTAL PROFESSIONAL FEES $2,357.50
TOTAL EXPENSES MADE TO YOUR ACCOUNT $28.72
TAXES
$0.00
PAYMENTS AND CREDITS $0.00
TOTAL BILL AMOUNT FOR INVOICE# 59459 $2,386.22
PREVIOUS BALANCE $23,855.03
INTEREST ON OVERDUE BALANCE $0.00
PLEASE PAY THIS AMOUNT(Please see attached invoice detail) $26,241.25
A 1 1/12%.PER MONTH REBILLING CHARGE WHICH IS AN ANNUAL RATE OF I S%WILL BE APPLIED APM 30 DAYS. FEDERAL I.D.125.1639294
PLEASE INDICATE YOUR INVOICE NUMBER ON YOUR REMITTANCE
UAV11N 1ZUZ
59459
2
INVOICE DETAIL
Inez Davis
c/o Gloria Banks
5776 Catherine Street
Harrisburg,PA 17112
Attention:
RE: Elder Law
DATE DESCRIPTION HOURS RATE AMOUNT
Feb-05-13 EBP Telephone call with DPW legal counsel 0.30 $275.00 $82.50
regarding consent;email to Gloria Banks
Feb-06-13 EBP Email exchanges with Jackie and Toya 0.20 $275.00 $55.00
regarding tax return;instruction to Toya
JBW NO CHARGE --Work on resolution of tax 1.20 $200.00 $0.00
notice,call IRS,file new return,type memo of
explanation.
Feb-07-13 JKD Telephone conversation with Gloria Banks 0.20 $125.00 $25.00
regarding notarized consensts and IRS consent
letter
Feb-12-13 EBP Preparation of praecipe and filing of consents 0.20 $275.00 $55.00
EBP NO CHARGE -attention to invoice; 0.20 $275.00 $0.00
conversation with Jackie
JKD NO CHARGE --Draft Praceipe 0.20 $125.00 $0.00
Feb-13-13 EBP NO CHARGE -Email correspondence with 0.30 $275.00 $0.00
Gloria regarding invoice•,conference with
Jackie Wolpert regarding IRS charges
EBP Instructions to Toya;attention to consents, 0.20 $275.00 $55.00
redaction thereof,and revision to praecipe
JKD Receive instructions from Elizabeth B.Place, 0.20 $125.00 $25.00
Esq.;draft cover letter regarding Praecipe
Feb-14-13 BJM NO CHARGE --call cumberland county 0.80 $125.00 $0.00
orphans'court for Praecipe filing fee;make
adjustments to enclosure letter;make copy for
correspondence subfile;scan and save to
pclaw;print postage.
Feb-21-13 BJM NO CHARGE --scan and save time-stamped 0.20 $125.00 $0.00
praecipe to server; file accordingly;
Mar-07-13 EBP NO CHARGE --Email to Gloria regarding 0.20 $275.00 $0.00
status request of Michael
VAVIINILUZ
59459
3
Mar-12-13 EBP NO CHARGE --Follow-up email to Gloria 0.10 $275.00 $0.00
regarding update to brother Michael
Mar-13-13 EBP NO CHARGE --Follow-up email to Gloria 0.20 $275.00 $0.00
regarding status request of Michael
Mar-14-13 JBZ NO CHARGE-Office conference with EBP 0.20 $300.00 $0.00
regarding update
EBP NO CHARGE --Emails from Gary and 0.20 $275.00 $0.00
Gloria regarding status update to Michael
EBP Telephone call with Gloria regarding status and 0.30 $275.00 $82.50
motion for final order
Mar-20-13 JBZ Review and revise EBP draft motion for Entry 0.20 $325.00 $65.00
of an Order
EBP Preparation of Motion. 0.30 $275.00 $82.50
EBP Telephone call with Gloria Banks regarding 0.40 $275.00 $110.00
care issues and motion for entry of order
JKD Receive instructions from Elizabeth B.Place, 1.00 $125.00 $125.00
Esq.;telephone conversation with Cumberland
County Courthouse regarding fees and
objections; correspondence to Cumberland
County Register of Wills regarding filing
Motion;prepare envelopes to mail to Register
of Wills along with petition;make copies for
paper file and certificate of service;scan and
save petition to file on the server
Mar-29-13 EBP Review of correspondence from IRS; 0.20 $275.00 $55.00
instructions regarding completing Form 2824
Apr-02-13 EBP Review of Order;telephone calls with Gloria 0.50 $275.00 $137.50
Banks regarding hearing;telephone message to
Ms.Rizzio,Jewish Home,regarding same
Apr-03-13 JBZ NO CHARGE-Emails to/from Elizabeth B. 0.20 $325.00 $0.00
Place,Esq.regarding update/hearing
EBP Conference with JBZ;message to Ruth,Judge 0.20 $275.00 $55.00
Peck's office; message to Diane Rizzio,Jewish
Home
Apr-04-13 EBP NO CHARGE --Travel to Gloria Banks 0.60 $275.00 $0.00
residence
EBP Meeting with Gloria and Gary Banks 1.00 $275.00 $275.00
EBP NO CHARGE --Two telephone messages to 0.20 $275.00 $0.00
Diane Rizzio
EBP Telephone call with Diane Rizzio 0.20 $275.00 $55.00
JKD NO CHARGE --Prepare pleadings index; 0.60 $125.00 $0.00
organize file on the server;scan and save
documents to file
1lHV L11V 1 LV L
59459
4
Apr-07-13 EBP Review of DPW regulations,preparation for 0.90 $275.00 $247.50
hearing;email to Gloria and Gary regarding
hearing preparation;call to CEO,Jewish Home
Apr-09-13 EBP Telephone call with Gloria Banks regarding 0.40 $275.00 $110.00
documentation and photographs;telephone call
with CEO,Jewish Home
EBP Extended email to Gloria regarding testimony; 2.00 $275.00 $550.00
preparation for hearing
EBP Attention to photos;telephone conversation 0.40 $275.00 $110.00
with Gary Banks
JKD NO CHARGE --Receive instructions from 0.80 $125.00 $0.00
Elizabeth B.Place,Esq.;pull tabs A-BB;print
petiton with 3 holes;assemble exhibit and
pleasding index
Professional Fees
$2,357.50
EXPENSES:
Postage $13.72
Mar 20/13 Cumberland County Register of Wills
filing fee for Motion Okd) $15.00
Total Expenses $28.72
Total Taxes Charged $0.00
Total due this invoice $2,386.22
Previous Balance $23,855.03
Payments received on previous balance $0.00
Interest due on overdue balance $0.00
Please Pay This Amount $26,241.25
A 1112%PER MONTHRESILLING CHARGE WHICH ISANANNUAL RATE OF 18%WILL BEAPPLIED AFTER 30 DAYS
FEDERAL I.D.#25-1839294
DAVIIN1202
LJNV 11N 1 LUL
59459
5
EXHIBIT G
SkarlatosZonarich LLC
17 S Second St, 6th Floor
Harrisburg Pennsylvania 17101
Telephone (717) 233-1000
Fax(717)233-6740
INVOICE SUMMARY
Inez Davis April 26, 2013
c/o Gloria Banks File#: DAVIIN1202
5776 Catherine Street Inv #: 59506
Harrisburg,PA 17112
Attention:
RE: Elder Law
TOTAL PROFESSIONAL FEES $1,154.00
TOTAL EXPENSES MADE TO YOUR ACCOUNT -$53.07
TAXES $0.00
PAYMENTS AND CREDITS $0.00
TOTAL BILL AMOUNT FOR INVOICE# 59506 $1,100.93
PREVIOUS BALANCE $26,241.25
INTEREST ON OVERDUE BALANCE $0.00
PLEASE PAY THIS AMOUNT (Please see attached invoice detail) $27,342.18
A 1 1/12%PER MONTH REBILLYNG CHARGE WHICH IS AN ANNUAL RATE OF 18%WILL BE APPLIED AFTER 30 DAYS. FEDERAL LD.425-1839294
PLEASE INDICATE YOUR INVOICE NUMBER ON YOUR REMITTANCE
59506
2
INVOICE DETAIL
iez Davis
o Gloria Banks
776 Catherine Street
arrisburg.PA 17112
ttention:
E: Elder Law
ATE DESCRIPTION HOURS RATE AMOUNT
pr-10-13 EBP Preparation of amended order;hearing exhibits 2.00 $137.00 $274.00
and binders(billed at paralegal rate)
EBP NO CHARGE --travel to Carlisle for hearing 1.00 $275.00 $0.00
EBP Meeting with Clients;Hearing 1.00 $275.00 $275.00
JKD NO CHARGE --Print color copies of photos; 1.20 $125.00 $0.00
assemble pleading and exhibit binder for
Gloria Banks
pr-11-13 JBZ NO CHARGE-Office conference with EBP 0.60 $325.00 $0.00
regarding hearing
EBP Email exchanges with Gloria regarding revised 0.50 $275.00 $137.50
Order and options for vehicle
EBP NO CHARGE --emails and return call to 0.20 $275.00 $0.00
Gloria
pr-12-13 EBP NO CHARGE --Telephone call with Gloria 0.50 $275.00 $0.00
regarding revised Order
pr-17-13 JKD NO CHARGE --Telephone Conversation with 0.20 $125.00 $0.00
Gary from Nationwide Insurance regarding
insuring an incapacitated person
pr-18-13 EBP Telephone calls with AAA regarding insurance 0.20 $275.00 $55.00
EBP NO CHARGE --Review of Court Order; 0.10 $275.00 $0.00
instructions to staff
EBP Telephone call with Gloria Banks regarding 0.50 $275.00 $137.50
Order and planning
JKD NO CHARGE --Scan and save Order to file 0.20 $125.00 $0.00
JKD NO CHARGE -- Telephone conversation with 0.20 $0.00 $0.00
Gary Jackson from Nationwide regarding
vechicle insurance
59506
or-19-13 EBP Email exchange with Gloria Banks regarding 0.20 $275.00 3 $55.00
car ownership
pr-22-13 EBP NO CHARGE --Research regarding auto 0.30 $275.00 $0.00
insurance and titling of car
pr-23-13 EBP no charge -- conference with Lisa Dougan, 0.00 $275.00 $0.00
Achieva regarding titling of vehicle; out of
state trusts
EBP NO CHARGE --Message from and to Gloria 0.20 $275.00 $0.00
EBP Telephone call with Gloria Banks regarding car 0.20 $275.00 $55.00
and insurance
or-25-13 EBP Review of insurance quote and drafting revised 0.60 $275.00 $165.00
petition.
EBP NO CHARGE --Telephone call with Gloria 0.40 $275.00 $0.00
regarding insurance,cost of repair etc
Professional Fees
$1,154.00
XPENSES:
Apr 26/13 Expense Recovery
postage refund -$53.07
Total Expenses -$53.07
Total Taxes Charged $0.00
Total due this invoice $1,100.93
Previous Balance $26,241.25
Payments received on previous balance $0.00
Interest due on overdue balance $0.00
Please Pay This Amount $27,342.18
1112%PER MONTH REBILLING CHARGE WHICH IS AN ANNUAL RATE OF 18%WILL BE APPLIED AFTER 30 DAYS.
MERAL LD,#25-1839194
1 VIIN1202
EXHIBIT H
CERTIFICATE OF CONSENT
I, Gloria J. Banks, daughter and Guardian of Inez H. Davis, do hereby certify that I have
reviewed the attached Petition, concur therewith, join in the Petition and pray that this court
approve it.
Dated: 92�/ 30
1, CO3 jl"Awz��Gloria J. , Petitioner
CERTIFICATE OF SERVICE
1, Jatoya Dayton, an employee with the law firm of SkarlatosZonarich LLC, hereby
certify that I this day served a copy of the foregoing SUPPLEMENTAL PETITION FOR
ALLOWANCE OF DISTRIBUTION OF PRINCIPAL upon the person(s) indicated below by
United States Mail,postage prepaid, at Harrisburg, Pennsylvania, and addressed as follows:
Gloria J. Banks Donald Ray Davis
5776 Catherine St. 927 Cabrera
Harrisburg,PA 17112 San Bernadino, CA 92411
Carolyn A. Henderson Michael Anthony Davis
16838 Ceres Ave., Apt. 106 22015 Cherokee Rd.
Fontana, CA 92335 Apple Valley, CA 92376
Elsie L. Baker Katheryn L. Alvarez
7367 Central Ave., #152 1933 Lenox St.
Highland, CA 92346 Harrisburg, PA 17104
Addie A.Abelson, Esq.
Office of Chief Counsel
Department of Public Welfare
3rd Floor West,Health& Welfare Building
7th and Forster Streets
Harrisburg, PA 17120
Date: April.°, 2013
4Jato Dayton