HomeMy WebLinkAbout08-02-13 �
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Jillian M.Golden
ph('717}233-5731
R.HQAI�S 8� SI��� LLP � �71��23s-s6az
jgolden@rhaads-sinon.com
� FIL6N0: 127S7/O1
7uly 31, 2Ci13
Re: In Re; Walter F. Raab Living Trust, Orphans' Court No. 21-12-398;
In Re: Bernice J. Raab Living Trust, Orphans' Court No. 21-12-399; and
In Re: Estate of Bernice J. Raab, Orphans' Caurt No. 21-11-$42
Hanorable Thamas J. Placey �,, �' "'' �
Cumberland County Caurt af Cornmon Pleas � c-;�
Cumberland County Courthouse � =.' , , ,
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One Caurthouse Square � �,,. ��
Carlisle, PA 17013 :�. 'w`�
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Dear Judge Placey: ` ' �; � � �
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We represent Wendy Robbins, Co-Executrix and Co-Trustee of t�'ie above-referenced
Estate and Trusts {"Ms. Robbins"}. C}n Ju1y 23, 2013, Ms. Robbins filed a Petition for
Appointment of Ivo V. Otto, III as Limited Administrator Pro Tem of the Estate of Bernice J.
Raab and Limited Trustee Pra Tem af the Walter F. Raab Living Trust and Bernice J. Raab
Living Trust Pursuant to 20 Pa. C.S.A. §4301. The Petition was served on counsel of recard for
the Respandents, Mandy Raab Carson and Laurie Ann Kucher (collectively "Respondents"}. The
Petition is currently befare your Honor awaiting issuance of a Rule to Show Cause.
Briefly, Ms. Rabbins and Respondents are sisters and the appointed and acting Co-
Executrices of the Estate and Co-Trustees of the Trusts. Tliey are alsa equai co-beneficiaries of
the Estate and Trusts. Administration has been ongoing since 2011, yet during this time, and
despite much effart, the fiduciaries are simply unable ta agree to the distributian of the mast
significant Estate and Trust assets (cash and marketable securities, personal property and real
property located in Florida and New Jersey}. Given these facts, and thase more fu11y set forth in
the Petition, Ms. Robbins is requestin� that the Caurt appoint a ternporary fiduciary to handle
only those issues to which the acting fiduciaries cannot agree. Ms. Rabbins is not requesting
removal of any of the fiduciaries, and she is hopeful that once the majar disputed issues are
addressed,the fiduciaries can wind up administration and close the Estate and Trusts.
The inability of the acting fiduciaries to cooperate on certain issues is c�bvious on the face
af the Petition, and we do nat expect Respondents to challenge the fact that the parties have been
unable to reach an agreement an these issues. Nor do we expect Respandents to contest the fact
that administratian has been delayed and communications between the fiduciaries have become
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July 31, 2013
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increasingly hostile. Therefore, we respectfully request that the Caurt schedule a status
conference in this matter as soon as possible, We believe that a status conference wiii assist in
narrowing the issues ta be addressed and will help to lnove this matter towards a prompt
resolution, which is in the best interest af ali parties and the Estate and Trusts.
We thank you far your attention to this matter.
Very truly yaurs,
R�-toaDS&Sl�vorr LLP
8�,: �- ��!!�'�
J lian M. Golden
cc: Wendy Robbins
Neil Hendershot, Esquire
Thomas A. French, Esquire