HomeMy WebLinkAbout06-04-13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
c 10 <-' z m
REGISTER OF WILLS c m
m � � O
rn o z (n
No. 2012-01011 n z m s z o
Cn
• � 0 0
ESTATE OF RAYMOND H. MATTSON, DECEASE o o r -n
-° C= = c�
PETITION TO ADMIT TO PROBATE A PHOTOCOPY 6F-WILL c) r rn
�y f,1 in O
TO THE REGISTER OF WILLS OF CUMBERLAND COUNTY:
The Petition of John Raymond Mattson respectfully states:
I. The Petitioner is the son of Raymond H. Mattson, ("Decedent") who died a
resident of Cumberland County, Pennsylvania,on September 15, 2012.
2. Petitioner resides at 7600 Baja Cove, Austin,Texas 78759.
3. Decedent was survived by Petitioner and the following additional next of kin:
(a) His wife, Romayne F. Mattson, who resides at Country Meadows of the
West Shore, 4905 E. Trindle Road, Mechanicsburg, PA 17050.
(b) His son, Scott Marshall Mattson, who resides at 21122 Greenbriar Lane,
South Lyon, MI 48178.
(c) His daughter, Barbara lean Mattson, who resides at 4753 Olentangy River
Road, Apartment H, Columbus, OH 43214-1963.
(d) His daughter, Virginia Ruth Mattson Carden, who resides at 100 Barons
Glen Way, Cary, NC 27513.
4. On October 6, 2004, Decedent executed a will, a copy of which is attached
hereto as Exhibit A, wherein it named his wife, Romayne F. Mattson, as
executrix; and his daughter, Barbara Jean Mattson, and his son, Scott Marshall
Mattson, as successor executors in that order.
5. The will was prepared by Decedent's attorney, Steven C. Wilds, Esquire, and
was witnessed by his said attorney and two other persons, Denise B.
Williamson and Paula A. Kalinowski.
6. Following the execution of the will by Decedent, the will was photocopied
and one photocopy was retained in the attorney's files and others were
provided to Decedent including one found among his personal effects after his
death.
7. The original will is believed by Petitioner never to have been in Decedent's
possession, but that it was retained by his attorney, Steven C. Wilds, Esquire,
who was in possession of the original Codicil referred to below at the time
Decedent died.
8. On August 1, 2012, Decedent executed a Codicil to his Last Will and
Testament dated October 6, 2004,whereby he amended and restated Section
4.1 of Article Four(Appointment of Fiduciaries), appointing Petitioner John
R. Mattson as Executor of said will; and his daughter, Barbara Jean Mattson,
and his son, Scott Marshall Mattson, as successor executors in that order.
9. Said Codicil was prepared by Decedent's attorney, Steven C. Wilds, Esquire,
and witnessed by Kristie Blomske. The original Codicil is now in the
possession of Petitioner's attorneys, Smigel, Anderson & Sacks, LLP, and will
be offered for probate.
2
10. Petitioner and his attorneys have made a diligent effort to find the missing
will, assuring that Decedent's said attorney made a thorough search of his
office and files; having Decedent's wife,by and through her attomey-in-fact,
search her personal effects and a safe deposit box at Fulton Bank,held in the
name of Decedent and his wife, in an effort to find the will; and a search of
Decedent's personal effects by the Petitioner. Despite these efforts, the
original Will could not be found.
11. Petitioner believes and avers that all of the Decedent's next of kin are in
agreement with this Petition and support the probate of the photocopied will.
WHEREFORE, petitioner respectfully requests that a citation issue directed to
Romayne F. Mattson, Barbara Jean Mattson, Steven Marshall Mattson and to show
cause why a photocopy of the will dated October 6, 2004, of Decedent,Raymond H.
Mattson, should not be admitted to probate as if it were the original.
Date:
John Raymond Mattson, Petitioner
Roger M. Morgenthal, Aquire, PA
ID#17143
Smigel,Anderson & Sacks, LLP
4431 N. Front Street, 3`a Floor
Harrisburg, PA 17110
(717) 234-2401 x 161
rmorgenthal @sasllp.com
Attorney for Petitioner
3
VERIFICATION
I, JOHN R. MATTSON, hereby state that I am the Petitioner herein, and I hereby
verify that the statements made in the foregoing petition are true and correct to the best of
my information, knowledge and belief.
This statement is made pursuant to the penalties of 18 Pa. Cons. Stat. Ann. §4904,
relating to unsworn falsification to authorities.
Date:
4
i
LAST WILL AND TESTAMENT
OF
RAYMOND H. MATTSON
I, l4aymond H. Mattson, of Lemoyne, Cumberland County, Pennsylvania,
which I hereby declare to be my domicile, make this Will, hereby revoking all my former
Wills and Codicils.
Article One
Specific Bequest of Tangible Personal Property
§1.1 I may have placed with this Will or otherwise made known to my
Executor a separate writing giving certain items of personal property to certain
individuals. It is my intention that such items shall pass to such individuals to be
distributed by my Executor in accordance with such writing. In the absence of such
writing, or to the extent it is incomplete or ineffective,then all my property, real,
personal, and mixed, shall be distributed in accordance with Section 1.2 below.
§12 I bequeath to my wife, Romayne F. Mattson (hereafter my"Wife"), if
she survives me, all my tangible personal property not disposed of by Section 1.1
above, including, by way of illustration and not by way of limitation, my household
furniture and fumishings, paintings, books, automobiles,jewelry and personal effects.
§1.3 If my Wife does not survive me, I give and bequeath all of my
tangible personal property that would otherwise pass under§1.2 to my Children (as
defined herein)who survive me in as equal shares as practicable, to be divided among
them as they may agree. If they are unable to agree, my Executor shall make such
decision.
§1.4 To the extent possible, I bequeath any policies of insurance covering
specific items of my tangible personal property to the beneficiary entitled to the specific
item of property.
§1.5 1 direct that the expenses of storing, packing, shipping, insuring and
delivering any such property to the beneficiary entitled thereto shall be paid as an
administrative expense of my estate.
Page 1 of 9
ZX/-1181 T 'A''
��12�D
60 py
r
Article Two
Residual Estate
§2.1 All the rest, residue, and remainder of my estate, wherever situated,
I give, devise, and bequeath to the then acting trustee under the RAYMOND H.
MATTSON TRUST AGREEMENT dated October G , 2004, established by me, as
h
Grantor, and Raymond H. Mattson, as Trustee,wich Trust Agreement is presently in
existence and in full1orce and effect, to be held, administered; and distributed in
accordance with the provisions of said Trust Agreement, as the same may be hereafter
amended in writing.
§2.2 In the event the Trust Agreement set forth in Section 2.1 above is
not in existence or found to be invalid or ineffective, I give, devise, and bequeath all the
rest, residue, and remainder of my property, real, personal, and mixed, to the then
acting trustee under the aforementioned Trust Agreement, to be held by such trustee in
trust on the same terms and conditions as those specified in such trust as the same
existed at the time of execution of this Will or the last codicil thereto. I direct that no
bond be required of said trustee, or successor trustee, in such instance.
Article Three
Definitions
§3.1 As used in this Will,the following terms shall have the following
meanings:
§3.1.1 My"Children" shall mean my children, Barbara Jean Mattson of
Columbus, Ohio; John Raymond Mattson of Austin, Texas; Scott Marshall
Mattson of South Lyon, Michigan; and Virginia Mattson Carden of Cary,
North Carolina, and any other children of mine, natural or adopted.
§3.1.2 My"Issue" shall mean my Children and their descendants,
natural or adopted.
Article Four
Appointment of Fiduciaries
§4.1 1 appoint my Wife, Romayne F. Mattson, as Executor of this Will. If
my Wife is unable or unwilling to act or continue to act as my Executor, for any reason
whatsoever, I appoint my daughter, Barbara Jean:Mattson, to serve as Executor in her
place. In the event Barbara Jean Mattson is either unable or unwilling to act or continue
to act as my Executor, I appoint my son, Scott Marshall.Mattson, to serve as successor
Executor. All references herein to the "Executor" shall mean my originally appointed
Executor or my successor Executor, as the case may be.
Page 2 of 9
Y
§4.2 1 appoint the Executor then serving hereunder as Guardian of the
estates of any minor beneficiaries under this Will, including the proceeds of any life
insurance on my life payable to such minors and any other property, rights or claims
with respect to which I am entitled to appoint a guardian and have not otherwise
specifically done so. The Guardian shall have full authority to use such assets, both
principal and income, in any manner the Guardian shall deem advisable for the best
interests of the minor, including college, university and.graduate education, and
professional, vocational or technical training, without securing a court order.
§4.3 If at the time of my death I am serving as a custodian of any Uniform
Transfers to Minors Act or Uniform Gifts to Minors Act account and have the right to
appoint my successor, I appoint my Executor as my successor.
Article Five
Power of Fiduciaries
§5.1 No fiduciary under this Will shall be required to post bond or other
security for the faithful performance of the fiduciary's duties.
§5.2 Any such fiduciary shall have the following powers, in addition to
those given by taw:
§5.2.1 To invest in, accept and retain any real or personal property,
including bonds, notes, money market funds, general and limited
partnership interest, mortgages, and the stock of a corporate fiduciary or
its holding company, without restriction to legal investments;
§5.2.2 To sell, exchange or partition either at public or private sale and
upon such terms and conditions as my fiduciary may deem advantageous
to my Estate or a trust, any or all real or personal estate or interest therein
owned by the Estate or a trust severally or in conjunction with.other
persons or acquired after my death by my fiduciary and to consummate
said sale or sales by sufficient deeds or other instruments to the
purchaser or purchasers, conveying a fee simple title, free and clear of all
trust, and without obligation of the purchaser or purchasers to see to the
application of the purchase money or to make inquiry into the validity of
said sale or sales; also, to make, execute, acknowledge and deliver any
and all deeds, assignments, options or other writings which may be
necessary or desirable in carrying.out any of the powers conferred upon
my fiduciary in my Will;
§5.2.3 To enter into and execute agreements of sale and long-term
leases and ground leases for any duration;to hold, subdivide, improve
and develop real property; to continue, terminate or refuse to renew any
Page 3 of 9
existing leases, agreements, mortgages or other encumbrances;to settle,
compromise, negotiate, arbitrate, litigate or otherwise dispose of disputes.
concerning real property without court approval; to form and enter into
partnerships (general and limited) and corporations; and to vote interests
or shares therein;
§5.2.4 To mortgage, create a security interest in, pledge, or
hypothecate; to exchange or lease (including lease for a period extending
beyond the term of the trust created by this Will); or to license, publish or
otherwise dispose of any shares, notes, securities, real estate, minerals,
literary and other trust property upon such terms, cash or credit, or both,
as the fiduciary may deem advisable;
§5.2.5 To make application for licenses and other documents to the
proper local or state agencies, boards and bureaus;
§5.2.6 To employ agents, accountants, attorneys, property managers,
appraisers, contractors, engineers, architects, surveyors, real estate
consultants, brokers and assistants and to pay their fees and expenses,
as the Executor may deem necessary or advisable to carry out the
provisions of this Will;
§5.2.7 To participate in any reorganization, consolidation, merger or
dissolution of any partnership, or corporation, the stocks, bonds or other
securities of which may be held at any time as part of the trust property,
and to receive and continue to hold any property which may be allocated
or distributed to the fiduciary by reason of participation in any such
reorganization, consolidation, merger or dissolution;
§5.2.8 To vote any shares of stock which form a part of my Estate or a
trust and to otherwise exercise all the powers incident to the ownership of
such stock;
§5.2.9 To assign to and hold in a trust an undivided portion of any
asset;
§5.2.10 To borrow money from any person, including any fiduciary
acting hereunder if such loans are upon reasonable commercial terms,
and to mortgage or pledge any real or personal property;
§5.2.11 To hold shares of stock or other securities in nominee
registration form, including that of a clearing corporation or depository, or
in book entry form or unregistered or in such other form as will pass
delivery;
Page 4 of 9
r
§5.2.12 To engage in litigation and to compromise, arbitrate or
abandon claims without court approval;
§5.2.13 To make distributions in cash, or in kind or partly in each, at
current values, allocating specific assets to particular distributees on a
non-pro rata basis, and for such purposes to make reasonable
determinations of current values;
§5.2.14 To make elections, decisions, concessions and settlements in
connection with all income, estate, inheritance, gift or other tax returns
and the payments of such taxes, without obligation to adjust the
distributive share of income or principal of any person affected thereby;
§5.2.15 To the extent economically beneficial to my estate,to join with
my Wife or her personal representative in the filing of a joint income tax
return for any period for which such a return may be permitted, without
requiring her estate to indemnify my estate against liability for the tax
attributable to her income, and to consent, for federal gift tax purposes, to
having gifts made by my Wife during my lifetime treated as having been
made half by me;
§5.2.16 To allocate, in the Executor's sole and absolute discretion,
any portion of my exemption under Section 2631(a)of the Internal
Revenue Code (which statutory exemption is presently$1,000,000.00),to
any property as to which I am the transferor, including any property
transferred by me during my lifetime as to which I did not make an
allocation prior to my death;
§5.2.17 To disclaim in whole or in part any interest I may have in any
estate if the Executor deems such disclaimer to be in the best interests of
my estate and beneficiaries thereof; and
§5.2.18 To merge, after the death of my Wife, any trust created
hereunder with any other trust or trusts created by me or my Wife, under
will or deed, if the terms of any such trust are substantially similar and are
held for the primary benefit of the same persons, and if such merger shall
not cause an adverse income, estate or generation-skipping transfer tax
consequence.
Article Six
Provision for Debts, Expenses and Taxes
§6.1 My Executor shall pay all expenses of my last illness and funeral,
costs of administration, including costs of safeguarding and delivering bequests and
other proper charges against my estate. My Executor shall pay all taxes assessed by
}
Page 5 of 9
f
reason of my.death (except that amount, if any, by which the estate and inheritance
taxes shall be increased as a result of inclusion of property which I may have a power
of appointment shall be paid by the person holding or receiving the property), including
interest and penalties thereof,from my residuary estate or, in the manner hereinafter
provided, from the trust estate of the trust created under the Trust Agreement identified
in Article Two hereof. Interest and penalties concerning any tax shall be paid and
charged in the same manner as the tax.
§6.2 1 have directed the trustee under the Trust Agreement of even date
herewith to pay to my Executor such amounts as my Executor shall request in writing as
necessary or advisable to supplement my probate estate in order to pay in full all debts,
bequests, funeral, and administrative expenses, federal and state income taxes, and
any tax which may be imposed by reason of my death. I authorize my Executor to
request such trustee to make all such payments to my Executor to the extent so
requested by my Executor; provided, however, that if any bonds issued by the United
States which may be redeemed at par in payment of federal estate taxes, and any
interest and penalties thereon due by reason of my death are held by such trustee,
such trustee shall utilize such bonds for the payment of same, to the extent such bonds
are redeemable for such payment or to the extent of the par value and accrued interest
on such bonds, whichever is less, regardless of the sufficiency of other assets in my
estate to pay the same.
§6.3 My Executor shall make such elections under the tax laws as my
Executor deems advisable, without regard to the relative interests of the beneficiaries.
No adjustment shall be made between principal and income or in the relative interests
of the beneficiaries to compensate for the effect of elections under the tax laws made
by my Executor or by the trustee under the Trust Agreement herein mentioned.
§6.4. My Executor shall have full power and authority to make the election
described in Section 2056(b)(7)of the Internal Revenue Code of 1986 or the
corresponding provisions of any further United States internal revenue law in respect of
all qualified terminable interest property(or any specific portion thereof) ineludible in my
gross estate,to such extent as my Executor shall deem to be in the best interests of my
estate and the beneficiaries thereof, and any determination made in good faith by my
Executor to make or not to make such election shall be binding and conclusive upon
each person having any interest in my estate and shall not be subject to questions or
exception in any manner or proceeding whatsoever,or by any person whomsoever.
Article Seven
Miscellaneous Provisions
§7.1 As used in this Will, the terms "Internal Revenue Code"and the
"Code" shall mean the Internal Revenue Code of 1986, as amended from time to time,
or the corresponding provisions of subsequent law.
Page 6 of 9
§7.2 If any beneficiary under this Will and I die under such circumstances
that it is impossible to determine which of us survived,or if any such beneficiary shall ;
fail to survive me for ninety (90)days, it shall be conclusively presumed and this Will . I
shall be construed as if such beneficiary predeceased me.
§7.3 A corporate fiduciary shall be entitled to receive compensation for its is
services hereunder in accordance with its schedule in effect when the services are
performed, but not in excess of such compensation as would be provided by a court of
competent jurisdiction. An individual fiduciary shall be entitled to receive reasonable I
compensation for such fiduciary's services hereunder.
i
IN WITNESS WHEREOF, I have hereunto set my hand and seal this ;
h' day of October, 2004. / 1� iJ
Ra and H. Mattson
Signed sealed, published and declared by the above-named Testator,
Raymond H attson, as and for his last Will, in the presence of us and each of us,who
at his requ s and in his presence and in the presence of each other, have hereunto
subscrib ur na �jessaas witnesses thereto and the day and year last above written.
Residing at a`1ss rt�pl4 ¢•-�d
CA M j 1,{.;11 GA 1-7011
Residing at 99 (A Ida OD%Qe� A ,e.
^ Fhtl FP C701i
Residing at(ND
Oxrl A [qi0 t
Page 7 of 9
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
I, Raymond H. Mattson,the Testator whose name is signed to the
foregoing instrument, having been duly qualified according to law, do hereby
acknowledge that I signed and executed the instrument as my Last Will; and that I
signed it willingly and as my free and voluntary act for the purposes therein expressed.
Sworn to or affirmed and acknowledged before me by Raymond H.
Mattson,the Testator, this K' day of October, 2004.
Ra and H. Mattson, Testator
I /n
Notary Public
My Commission Expires: '11121ma
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Harva Owings Baughman,Notary Public
City bt Hasbmg. Dauphin County
My Comm mWon Expires luty.12,2008
Member.Pennsylvania Association of Notarles
i
E
Page 8 of 9
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
////�� 1 , i ,;tsQ. P� t ctu,:, and
I�1• l the witnesses whose names are signed to the attached or
foregoing instr ment, being duly qualified according to law, do depose and say that we
were present and saw the Testator sign and execute the instrument as his Last Will;
that each subscribing witness, in the hearing and sight of the Testator, signed the Will
as a witness; and that to the best of our knowledge,the Testator was at that time 18 or
more years of age, of sound mind and under no constraint or undue influence.
$worn to or affirmed and subscribed to befrmeby ud(ld�,Qup�c¢ JW,kl,tt �srl and ill Sit ,
witnesses, this Cam•', day of October, 2004.
Witnes
LU
n ss
I
i
Notary.Public °
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
F:WbMWi1IsWattson 1Raymond-WILL.doe Notarial Seal
Harva Owings Baughman, Ni Public
City of Hnrtitburg. Dauphin County
My Commission Fxpim July IZ 2008
i Member,Pen %)Mnla Assoaagon or Notules
i
{
i
Page 9 of 9
i
CODICIL TO THE
LAST WILL AND TESTAMENT OF
RAYMOND H. MATTSON
I, Raymond H. Mattson, of Lemoyne, Cumberland County, Pennsylvania, being of
sound and disposing mind and memory, do make, publish and declare this Codicil to my
Last Will and Testament dated October 6, 2004 (hereinafter my"Will').
Section 4.1 of Article Four(Appointment of Fiduciaries) is hereby amended
and restated in its entirety, as follows:
§4.1 1 appoint my son, John R. Mattson, as Executor of this Will. If
John R. Mattson is unable or unwilling to act or continue to act as my
Executor, for any reason whatsoever, 1 appoint my daughter, Barbara
Jean Mattson, to serve as Executor in her place. In the event Barbara
Jean Mattson is either unable or unwilling to act or continue to act as my
Executor, I appoint my son, Scott Marshall Mattson, to serve as successor
Executor. All references herein to the "Executor" shall mean my originally
appointed Executor or my successor Executor, as the case may be.
In all other respects, my Will shall continue and remain in full force and effect.
IN WITNESS WHEREOF, I have hereunto set my hand and seal to this
Codicil to my Will, consisting of three pages, this 1 64-day of
�a
12012.
Ray�ti and H. Mattson
(Y II
Page 1 of 3 Z--Xi 18 I T 13
SIGNED, SEALED, PUBLISHED AND DECLARED by the above-
named Testator, Raymond H. Mattson, as and for a Codicil to his Will, in the presence of
us, who, at his request, in his presence, and in the presence of each other, have hereunto
subs ribed our names a witnesses in attestation thereof.
i
Addressi 09 E h S Add'
Address 4Strt --ne,ret.n1,-d Dr.
I.Ili✓t' 9, P-A 1111/0
COMMONWEALTH OF PENNSYLVANIA :
: SS.
COUNTY OF
1, Raymond H. Mattson, the Testator whose name is signed to the attached
or foregoing instrument, having been duly qualified according to law, do hereby
acknowledge that I signed and executed the instrument as a Codicil to my Last Will and
Testament; and that 1 signed it willingly and as my free and voluntary act for the purposes
therein expressed.
Sworn to or affirmed and acknowledged before me by Raymond N. Mattson,
this 1�� day of_ 4a-!j js+- . 2012.
All
c s�io Testator
C6MMONwt+ALTH aF PGNI IM YAN(h
Y Nfris La7vol ry .
Lisa M.Sites,Notary A+biic
City of Harrisburg,Dauphin County lrQ M -
M eca3missmnea iresA vL28,20(3 a Public
My Commission Expires:
Page 2 of 3
I
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF SS.
We, Steven C. Wilda and Kristie Blomske the
witnesses whose names are signed to the attached or foregoing instrument, being duly
qualified according to law, do depose and say that we were present and saw the Testator
sign and execute the instrument as a Codicil to his Last Will; that the Testator signed
willingly and executed it as his free and voluntary act for the purposes therein expressed;
that each subscribing witness, in the hearing and sight of the Testator, signed the Codicil
as a witness; and that to the best of our knowledge, the Testator was at that time 18 or
more years of age, of sound mind and under no constraint or undue influence.
Sworn to or affirmed and subscribed to before me by
Steven C. Wilds and Kristie Blomske
August this 1st day of
' 2012.
JuOic
� � �
My Commission Expires:
COMMOMYEALTR OF PENNSYLVANIA
NOTARIAL SEAL
Liss M.Site"14 otary Public
Cily of llai risbm8,Dauphin County
M co`yranission SU,,f ,A ril Y8,2011
F:\dbw\Wills\Kattcon\Raymond - Codicil aola.doo
Page 3 of 3