HomeMy WebLinkAbout12-04-13 ESTATE OF ELIZABETH H. VANDERGRIFT : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
Executor NO. 2013-00750
PETITION TO SUBSTITUTE TRUSTEE OF TESTAMENTARY TRUST
AND NOW comes Petitioner, Craig L. Vandergrift, by and through his attorney,
Jacqueline A. Kelly, of the law office of Jan L. Brown and Associates, and files this Petition to
Substitute Trustee of Testamentary Trust and in support hereof avers as follows:
1. Petitioner, Craig L. Vandergrift, has been duly appointed as Executor of the
Estate of Elizabeth H. Vandergrift, who died July 2, 2013.
2. The Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013 was
admitted to probate and is recorded in Cumberland County Courthouse, Register of Wills, File
No. 2013-00750.
3. Under the Last Will and Testament of Elizabeth H. Vandergrift, Craig L.
Vandergrift, Debra G. Graham, and Susan L. Mease are named as beneficiaries of the residuary
estate.
4. Under Article V of the Last Will and Testament of Elizabeth H. Vandergrift,
Debra G. Graham is entitled to a specific.bequest of the real property located at 11 Blackmore
Court, Camp Hill, Pennsylvania, wherein which a testamentary trust is established fof3his a
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5. The testamentary trust for the benefit of Debra G. Graham under the Last Will
and Testament of Elizabeth H. Vandergrift appoints Craig L. Vandergrift and/or Nathan Shuman,
as the Co-Trustees.
6. Craig L. Vandergrift has decided to renounce his position as Co-Trustee of the
testamentary trust for the benefit of Debra G. Graham under the Last Will and Testament of
Elizabeth H. Vandergrift. See Renunciation of Trustee dated November 12, 2013 attached hereto
and marked as Exhibit A.
7. Andrea Shuman, wife of Co-Trustee Nathan Shuman, has agreed to act as a
substitute Co-Trustee, in place of Craig L. Vandergrift, for the testamentary trust for the benefit
of Debra G. Graham under the Last Will and Testament of Elizabeth H. Vandergrift. See
Acceptance of Trust dated November 4, 2013 stating her acceptance to act as Co-Trustee
attached hereto and marked as Exhibit B.
8. Craig L. Vandergrift, as Executor and a residuary beneficiary of the estate, has
signed a statement acknowledging his agreement to the substitution of Andrea Shuman as Co-
Trustee of the testamentary trust for the benefit of Debra G. Graham under the Last Will and
Testament of Elizabeth H. Vandergrift. See attached Statement of Agreement marked as
Exhibit C.
9. Debra G. Graham, as a residuary beneficiary of the estate and as a beneficiary of
the testamentary trust, has signed a statement acknowledging her agreement to the substitution of
Andrea Shuman as Co-Trustee of the testamentary trust for her benefit under the Last Will and
Testament of Elizabeth H. Vandergrift. See attached Joinder and Statement of Agreement
marked as Exhibit D.
10. Susan L. Mease, as a residuary beneficiary of the estate, has signed a statement
acknowledging her agreement to the substitution of Andrea Shuman as Co-Trustee of the
testamentary trust for the benefit of Debra G. Graham under the Last Will and Testament of
Elizabeth H. Vandergrift. See attached Joinder and Statement of Agreement marked as
Exhibit E.
11. Nathan Shuman, as Co-Trustee, has signed a statement acknowledging his
agreement to the substitution of Andrea Shuman as Co-Trustee of the testamentary trust for the
benefit of Debra G. Graham under the Last Will and Testament of Elizabeth H. Vandergrift. See
attached Joinder and Statement of Agreement marked as Exhibit F.
12. WHEREFORE, Petitioner requests this Honorable Court to enter an Order,
pursuant to the Probate, Estates, and Fiduciary Code, 20 Pa. C.S.A. §7101 et al., substituting
Andrea Shuman as Co-Trustee of the testamentary trust for the benefit of Debra G. Graham
under the Last Will and Testament of Elizabeth H. Vandergrift in place of Craig L. Vandergrift.
Respectfully submitted,
JAN L. BROWN& ASSOCIATES
Date: oRbl,3 By: —A
.4a gaeV e A. Kelly, Esquire
Attorney I.D. No. 91973
845 Sir Thomas Court, Suite 12
Harrisburg, PA 17109
(717) 541-5550
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of L8 Pa.C.S. Section 4904, re ing to
unswom falsification to authorities. -- ---
CRAIG L. VANDERGRIFT
ESTATE OF ELIZABETH H. VANDERGRIFT : IN THE COURT OF COMMON PLEAS
CUMBERLAND-COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIV ION
CRAIG L. VA DERGRIFT,
Executor : NO. I - 0 50
ER FICA O
I, Jacqueline A.Kelly,Esqui certi that on 2013, I served a true
and correct copy of the within Petition S stitute Trustee of Testamentary Trust on the parties
named below, by deposing same in the d States mail, first class,postage prepaid, addressed
as follows:
Craig L.Vandergrift Na an Shuman and Andrea Shuman
1545 Beechwood Boulevard 121 S rman Avenue
Pittsburgh,PA 15217 Teaneck, J 07666
Debra G. Graham
11 Blackmore Cc rt
Camp Hill, PA 7011
Susan L. ase
417 East arble Street
Mechanicsburg, PA 17055
By:
Jacqueline A. Kelly,Esquire
845 Sir Thomas Court, Suite 12
ESTATE OF ELIZABETH H. VANDERGRIFT IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
Executor NO. 2013-00750
CERTIFICATE OF SERVICE
I, Jacqueline A. Kelly, Esquire, certify that on /Q --3 , 2013, I served a true
and correct copy of the within Petition to Substitute Trustee of Testamentary Trust on the parties
named below, by deposing same in the United States mail, first class, postage prepaid, addressed
as follows:
Craig L. Vandergrift Nathan Shuman and Andrea Shuman
1545 Beechwood Boulevard 121 Sherman Avenue
Pittsburgh, PA 15217 Teaneck,NJ 07666
Debra G. Graham
I 1 Blackmore Court
Camp Hill, PA 17011
Susan L. Mease
417 East Marble Street
Mechanicsburg, PA 17055
By:
9cquel' e A. Kelly, Esquire
845 Sir Thomas Court, Suite 12
Harrisburg, PA 17109
(717) 541-5550
RENUNCIATION OF TRUSTEE
The Last Will and Testament of Elizabeth H.Vandergrift dated June 20, 2013 was
admitted to probate and is recorded in Cumberland County Courthouse, Register of Wills, File
No. 2013-00750. Under Article V of the Last Will and Testament of Elizabeth H.Vandergift, a
testamentary trust is established for the share of Debra G. Graham, wherein CRAIG L.
VANDERGRIFT and/or NATHAN SHUMAN were named as Co-Trustees.
WHEREAS, CRAIG L. VANDERGRIFT has decided to renounce his position as Co-
Trustee of the testamentary trust for the benefit of Debra G. Graham.
NOW,THEREFORE, the undersigned, CRAIG L. VANDERGRIFT renounces
appointment as Co-Trustee of the testamentary trust for the benefit of Debra G. Graham under
the Will of Elizabeth H.Vandergrift dated June 20, 2013.
Executed this./'2- day of , ✓v..� 2013.
filljov
tkAIG A ERGRIF
COMMONWEALTH OF PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA Notarial seal
Jay Wzer,Notary Public
SS: Sew ddey eoro,Allegheny County
My Commission FxPlre9]uly N U 2015
COUNTY OF MEMBER,pENN$YLVANIA ASSOQATION OF NOrAiU6
On this the 17. .day of ✓ca,Lto, 2013 before me, a Notary Public,the
undersigned officer,personally appeared CRAIG L. VANDERGRIFT, known to me or
satisfactorily proven to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my lion d official seal.
ACCEPTANCE OF TRUST
The Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013 was
admitted to probate and is recorded in Cumberland County Courthouse, Register of Wills, File
No. 2013-00750. Under Article V of the Last Will and Testament of Elizabeth H. Vandergift, a
testamentary trust is established for the share of Debra G. Graham, wherein CRAIG L.
VANDERGRIFT and/or NATHAN SHUMAN were named as Co-Trustees.
WHEREAS, CRAIG L.VANDERGRIFT renounced his position as Co-Trustee by
document dated NCVpA&1 2013.
NOW, THEREFORE, the undersigned,ANDREA SHUMAN accepts appointment as
Co-Trustee and agrees to serve as such in accordance with the terms and provisions of said
testamentary trust for the benefit of Debra G. Graham.
Executed this day of Od2rnb2i2, 2013.
A REA SHUMA
STATE OF NEW JERSEY
SS:
COUNTY OF �_--
On this the.. *ll day of U ro )bQPZ , 2013 before me, a Notary Public, the undersigned
officer,personally appeared ANDREA SHUMAN, known to me or satisfactorily proven to be the
person whose name is subscribed to the within instrument, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my, hand and official seal.
1�0 rfQ Lrl'
Notary Public
Brenda Palmer
Notary Public
New Jersey
My Commission Expires 2-21-16
No.2430264
ESTATE OF ELIZABETH H.VANDERGRIFT: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
Executor : NO. 2013-00750
STATEMENT OF AGREEMENT
I, Craig L. Vandergrift,as Executor and as a residuary beneficiary under the Last
Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013,hereby agree to the
substitution of Andrea Shuman, in place of Craig L.Vandergrift, as Co-Trustee of the
Testamentary Trust f/b/o Debra G. Graham under the Last Will and Testament of
Elizabeth H. Vandergrift.
I also agree to the terms of the Testamentary Trust f/b/o Debra G. Graham under
the Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013, and I have
no objections to Andrea Shuman, as Co-Trustee of the Testamentary Trust f/b/o Debra G.
Graham, executing the terms of the trust as stated under the Last Will and Testament of
Elizabeth H. Vandergrift dated June 20, 2013. I also hereby waive any future rights to
object to Andrea Shuman acting as Co-Trustee.
D ted:
CRAI L. VANDERGRIF
ESTATE OF ELIZABETH H. VANDERGRIFT: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
-Executor NO. 2013-00750
JOINDER and STATEMENT OF AGREEMENT
I,DEBRA G. GRAHAM,join in this Petition to Substitute Trustee of
Testamentary Trust filed by Craig L. Vandergrift to have Andrea Shuman substituted as
Co-Trustee, in place of Craig L. Vandergri t, of tife testamentary trust for the benefit of
Debra G. Graham.
I,Debra G. Graham, as a residuary beneficiary under the Last Will and Testament
of Elizabeth H. Vandergrift dated June 20, 2013, hereby agree to the substitution of
Andrea Shuman, in place of Craig L. Vandergrift, as Co-Trustee of the Testamentary
Trust f/b/o Debra G. Graham under the Last Will and Testament of Elizabeth H.
Vandergrift. '
I also agree to the terms of the Testamentary Trust f/b/o Debra G. Graham under
the Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013, and I have
no objections to Andrea Shuman, as Co-Trustee of the Testamentary Trust f/b/o Debra G.
Graham, executing the terms of the trust as stated under the Last Will and Testament of
Elizabeth H. Vandergrift dated June 20, 2013. I also hereby waive any future rights to
object to Andrea Shuman acting as Co-Trustee.
Dated: ��Q� D 9 aci 6y",
DEBRA G. GRAHA __�__
ESTATE OF ELIZABETH H. VANDERGRIFT: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
Executor NO. 2013-00750
JOINDER and STATEMENT OF AGREEMENT
I, SUSAN L. MEASE,join in this Petition to Substitute Trustee of Testamentary
Trust filed by Craig L. Vandergrift to have Andrea Shuman substituted as Co-Trustee, in
place of Craig L. Vandergrift, of the testamentary trust foi•the benefit of Debra G.
Graham.
I, Susan L. Mease, as a residuary beneficiary under the Last Will and Testament
of Elizabeth H. Vandergrift dated June 20, 2013, hereby agree to the substitution of
Andrea Shuman, in place of Craig L. Vandergrift, as Co-Trustee of the Testamentary
Trust f/b/o Debra G. Graham under the Last Will and Testament of Elizabeth H.
Vandergrift.
I also agree to the terms of the Testamentary Trust f/b/o Debra G. Graham under
the Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013, and I have
no objections to Andrea Shuman, as Co-Trustee of the Testamentary Trust f/b/o Debra G.
Graham, executing the terms of the trust as stated under the Last Will and Testament of
Elizabeth H. Vandergrift dated June 20, 2013. I also hereby waive any future rights to
object to Andrea Shuman acting as Co-Trustee.
Dated: a
SUSAN L. MEASE
ESTATE OF ELIZABETH H. VANDERGRIFT: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
CRAIG L. VANDERGRIFT,
Executor NO. 2013-00750
JOINDER and STATEMENT OF AGREEMENT
I, NATHAN SHUMAN,join in this Petition to Substitute Trustee of
Testamentary Trust filed by Craig L. Vandergrift to have Andrea Shuman substituted as
Co-Trustee, in place of Craig L. Vandergrift, of the testamentary trust for the benefit of
Debra G. Graham.
I, Nathan Shuman, as a Co-Trustee of the testamentary trust for the benefit of
Debra G. Graham, hereby agree to the substitution of Andrea Shuman, in place of Craig
L. Vandergrift, as Co-Trustee of the Testamentary Trust f/b/o Debra G. Graham under the
Last Will and Testament of Elizabeth H. Vandergrift.
I also agree to the terms of the Testamentary Trust f/b/o Debra G. Graham under
the Last Will and Testament of Elizabeth H. Vandergrift dated June 20, 2013, and I have
no objections to Andrea Shuman, as Co-Trustee of the Testamentary Trust f/b/o Debra G.
Graham, executing the terms of the trust as stated under the Last Will and Testament of
Elizabeth H. Vandergrift dated June 20, 2013. 1 also hereby waive any future rights to
object to Andrea Shuman acting as Co-Trustee.
Dated: 3
NATHAN SHUMAN