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HomeMy WebLinkAbout04-08-14 RECORDED OFFICE OF REGISTER OF WILLS ECKERT SEAMANS CHERIN & MELLOTT, LLC 2014 P,?R 8 PM 1 34 ' Thomas P. Gacki, Esquire (PA I.D. #44864) 213 Market Street, 8'" Floor CLERK OF P. 0. Box 1248 ORPHANS' COURT Harrisburg, PA 17108-1248 CUMBERLAttD CO., PA Phone: 717.237.6093 Email: tgackiCaD-eckertsea mans.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF ROBERT ADLER, ORPHANS' COURT DIVISION DECEASED 21-12-00252 ANSWER OF NATALIIA ADLER TO PETITION TO REVOKE AB INITIO LETTERS OF ADMINISTRATION WITH NEW MATTER AND NOW comes Respondent, Nataliia Tykhonova Adler, and answers the referenced Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part and denied in part. It is admitted that Respondent signed a document purporting to be a pre-nuptial agreement and a copy of such document is attached to the Petition as Exhibit "1". It is denied that such document is legally effective in that it was presented to Respondent, two days prior to the wedding, in such a manner as she could not consult counsel, and under circumstances of duress. Respondent incorporates herein Respondent's New Matter.. By way of further answer, the referenced document speaks for itself. fL0547078.1) 6. Denied as a conclusion of law. 7. Denied as a conclusion of law. 8. Admitted. 9. Denied as a conclusion of law. 10. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself. 11. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself. 12. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself.. 13. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself. The Settlement Agreement is a legally binding document. 14. Denied as a conclusion of law. 15. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself. 16. Denied as stated. By way of further answer, the Settlement Agreement speaks for itself.. 17. Denied. (a) Respondent has not failed to disclose, conceal, and/or remove any assets of the estate. By way of further answer, the Settlement Agreement did not require her to disclose the assets of the estate in any event. (b) It is denied that Respondent has failed to distribute to Petitioner all of the assets to which Petitioner is entitled. Respondent incorporates herein Respondent's New Matter. 2 (c) Respondent has not failed to disclose, conceal, and/or remove any assets of the estate. By way of further answer, the Settlement Agreement did not require her to disclose the assets of the estate in any event. (d) It is admitted that Respondent has not paid Smith the sum of $14,000 referenced in the Settlement Agreement. By way of further answer, by the terms of the Settlement Agreement, such amount is not payable until the "closing of the estate" which has not yet occurred. Respondent incorporates herein Respondent's New Matter. (e) Denied. Petitioner took possession of the 2006 Mustang GT on July 6, 2012. Respondent delivered titles to and possession of all the other vehicles described in the Settlement Agreement to Petitioner's agent, David Cordier. (f) Denied. All of the valuable jewelry was located in Decedent's safe deposit box and was delivered to Petitioner on July 6, 2012 by Attorney Adler. There is some costume jewelry from the house that is waiting in the garage for Petitioner to pick up. Petitioner took possession of the silver and guns on July 7, 2012, except that Petitioner verbally agreed at the time that Respondent could retain one small handgun valued at $150. Respondent incorporates herein Respondent's New Matter. 18. Respondent has not failed to disclose, conceal, and/or remove any assets of the estate or wrongfully dispose of any assets of the estate. By way of further answer, the Settlement Agreement did not require her to disclose the assets of the estate in any event and Respondent is entitled to all of the assets of the estate except for those specifically earmarked for Petitioner in the Settlement Agreement. 19. Admitted in part and denied in part. It is admitted that Respondent filed the referenced Inventory, which speaks for itself. It is denied that Petitioner is entitled to any property of the estate except what is specifically identified in the Settlement Agreement. Respondent has not failed to disclose, conceal, and/or remove any assets of the estate. 20. Denied. Prior to entering into the Settlement Agreement, Petitioner and her counsel were supplied with an informal inventory of the estate, prepared by William 3 Adler, Esquire, attorney for the estate, that listed all the assets referenced in this paragraph of Petitioner's Petition. The informal inventory, cover email, and exhibits to the email transmitting the informal inventory are attached hereto as Exhibit "A". The Integrity Bank Certificate of Deposit with the exact value referred to in the Petition is the first item on the inventory. Respondent incorporates herein Respond'ent's New Matter.. 21. Denied. Petitioner obviously obtained a copy of the inventory since it is referred to in Petitioner's Petition. In any event, prior to entering into the Settlement Agreement, Petitioner and her counsel were supplied with the informal inventory of the estate attached hereto as Exhibit "A" which is consistent in all material respects with the formal inventory . Respondent incorporates herein Respondent's New Matter. 22. Denied as stated. By way of further answer, the Inheritance Tax Return speaks for itself. It is denied that it discloses any material assets that were not known or should have been known to Petitioner. 23. Denied as stated. The Inheritance Tax Return speaks for itself. It is denied that Petitioner is entitled to any property of the estate except what is specifically identified in the Settlement Agreement. 24. Denied as stated. By way of further answer, the referenced document speaks for itself. 25. Denied. Petitioner obviously obtained a copy of the inheritance tax return since it is referred to in Petitioner's Petition. 26. Denied as stated. Respondent did not fraudulently disclose, conceal or remove any assets of the estate. The referenced section of the Settlement Agreement 4 was not "inserted by Respondent"; it was written into the Settlement Agreement by Petitioner's own counsel. 27. Denied as stated. The quoted provision of the Settlement Agreement is not "problematic". 28. Denied. The terms of the IRA Agreement do make Respondent the death beneficiary of the IRA. Although her name does not appear on the beneficiary designation form, by the terms of the IRA Agreement, it was payable to the spouse of Robert Adler absent another living beneficiary being designated. Consequently Respondent received the IRA proceeds and they were not payable to the estate. 29. Denied as a conclusion of law. By way of further answer, the terms of the -Settlement Agreement and the beneficiary designation of the IRA control over the terms of the unenforceable Pre-Nuptial Agreement.. 30. Denied. Respondent incorporates herein Respondent's answer to paragraph 28 hereof. 31. Denied. Respondent incorporates herein Respondent's answer to paragraph 28 hereof. 32. Denied. There were no "fraudulent transfers". By way of further answer, Respondent believes that the referenced Primerica IRA is the "Chip Thrush IRA" disclosed to Petitioner prior to the execution of the Settlement Agreement— see page 2 of the informal inventory included in Exhibit "A" hereto, in that the amount referred to in the Petition matches to the penny.. 33. Denied. All of the assets referenced in this paragraph were fully disclosed to Petitioner as aforesaid. 5 34. Denied. All of the assets referenced in this paragraph were fully disclosed to Petitioner as aforesaid.. 35. Denied. All of the.assets referenced in this paragraph were fully disclosed to Petitioner as aforesaid. 36. Denied. All of the assets referenced in this paragraph were fully disclosed to Petitioner as aforesaid. Respondent was in fact the "true beneficiary" of the referenced IRA. 37. Denied. Respondent has not failed to disclose, conceal, and/or remove any assets of the estate.. 38. Denied as a conclusion of law. 39. Denied as a conclusion of law. 40. Denied. Respondent has note engaged in any fraudulent conduct and the settlement agreement, drafted by Petitioner's own counsel, is not fraudulent. 41. Denied that Respondent committed any fraud on the Register of Wills.. 42. Denied as a conclusion of law. 43. Denied as a conclusion of law. 44. Denied as a conclusion of law. NEW MATTER Respondent sets forth the following New Matter, which Respondent incorporates by reference.into each of the paragraphs set forth above. 1. Robert Adler-died suddenly and unexpectedly at the age of 50. 2. Prior to his death, Robert Adler and Petitioner were estranged. 6 i I I 13. Further, Respondent was financially reliant on Robert Adler and had no funds to retain her own attorney to represent her, and Robert Adler did not offer to help her pay for her own attorney. 14. Similarly, although the Pre-Nuptial Agreement contains boilerplate language to the effect that Respondent read and understood the agreement, this was not the case. 15. Respondent was not a native English speaker and although she had the ability to communicate in English, she did not have the capacity to read and understand a legal document like the Pre-Nuptial Agreement. 16. Neither Robert Adler nor his counsel attempted to explain the implications of the Pre-Nuptial Agreement, particularly the fact that Respondent would be rendered essentially penniless in the event of the death of Robert Adler if the Pre-Nuptial Agreement was enforceable. 17. Respondent had no idea at the time the Pre-Nuptial Agreement was executed that she was waiving her rights to inherit from her husband's estate. 18. The Pre-Nuptial Agreement is therefore voidable by Respondent on grounds of duress and lack of actual consent, among other grounds. 19. Following the death of Robert Adler, Petitioner retained the services of Ronald Butler, Esquire, a respected and experienced practitioner. 20. Ronald Butler was the draftsman of the Settlement Agreement. 21. The Settlement Agreement was predicated on the fact that Respondent had strong legal grounds to challenge the enforceability of the Pre-Nuptial Agreement. 8 22. If the Pre-Nuptial Agreement were void, Respondent would be the sole heir of Robert Adler, entitled to obtain letters of administration on his estate, and Petitioner would receive nothing from the estate. 23. Mr. Butler wrote the following in the Settlement Agreement: WHEREAS, Robert A. Adler and Adler executed a Pre- Nuptial Agreement under circumstances that the parties are not desirous of litigating including being presented with the Pre-Nuptial Agreement without counsel under circumstances of duress only two days before the wedding whereby Adler purportedly agreed to waive her rights to inherit from Robert A. Adler's Estate . . . 24. Consequently, the Settlement Agreement is a reasonable compromise by which Petitioner received substantial assets from the Robert Adler Estate she would not otherwise have received if Respondent had successfully challenged the Pre-Nuptial Agreement. 25. Nothing in the Settlement Agreement requires that Respondent resign or is to be removed as Administratrix of the estate. The Settlement Agreement provides as follows: The remainder of the assets shall remain with the Estate to be distributed by Adler as she determines, in her sole discretion . . . 26. This provision contemplates that Respondent would continue to act as administrator of the Estate of Robert Adler and Petitioner freely consented to that when she executed the Settlement Agreement. 27. Petitioner actually stayed at Respondent's house with her son for about a week, approximately from June 30, 2012 through July 7, 2012, when the Settlement Agreement was executed, and had unsupervised full access to the property. During this 9 time Petitioner drew up the list of property that she wanted that was subsequently incorporated into the Settlement Agreement. 28. Prior to entering into the Settlement Agreement, Petitioner and her counsel were supplied with the informal inventory of the estate, prepared by William Adler, Esquire, that is attached hereto as Exhibit "A". 29. The informal inventory prepared by Mr. Adler is consistent in all material respects with the assets of the estate as reported on the formal inventory and the inheritance tax return 30. Since the informal inventory disclosed the existence of the Integrity Bank Certificate of Deposit with the exact date of death value of$156,526.71 and the various bank accounts referred to in paragraph 28 of the Petition, and it was supplied to Petitioner prior to the execution of the Settlement Agreement, paragraph 28 of the Petition is patently false and Petitioner violated 18 Pa. C. S. Section 4904 when she signed the verification to the Petition. 31. If Petitioner and her counsel were concerned with the adequacy of the disclosures provided by Attorney Adler, they could have included specific representations and warranties by Respondent as to the assets of the estate in the Settlement Agreement. 32. There are no representations and warranties by Respondent as to the assets of the estate in the Settlement Agreement. To the contrary, the Settlement Agreement provides as follows: This Agreement and any accompanying instruments and documents represent the entire transaction between the parties hereto, and there are no representations, warranties, 10 covenants or conditions except those specified herein or in the accompanying instruments and documents. 33. Respondent has substantially performed her duties under the Settlement Agreement. To date, Petitioner has received the $115,000 payment due at the time the Settlement Agreement was executed, all the automobiles, and the cigarette boat. 34. All of the valuable jewelry was located in Decedent's safe deposit box and was delivered to Petitioner on July 6, 2012 by Attorney Adler. There is some costume jewelry from the house that is waiting in the garage for Petitioner to pick up. Petitioner took possession of the silver and guns on July 7, 2012, except that Petitioner verbally agreed at the time that Respondent could retain one small handgun valued at $150. 35. Respondent made considerable efforts to arrange with Petitioner to deliver the remaining items of personal property Petitioner is entitled to under the Settlement Agreement. There was considerable delay in this process because Petitioner resides in South Carolina. 36. In June 2013 Petitioner contacted Respondent and asked to come to her house in July 2013 to collect the remaining vehicles, a check for $14,000 and to pack the remaining items spelled out in the Settlement Agreement, since Petitioner indicated she would be in the area at that time for a reunion. Petitioner asked for subsequent visit in Fall 2013 to move the remaining items she indicated she would pack in the July 2013 visit. 37. The parties further agreed to meet at a AAA office in Camp Hill on July 12, 2013 to transfer the remaining cars' titles to Petitioner's name. 38. Twelve hours before the appointment, Petitioner contacted Respondent and expressed that she wanted to move out all the items that she is entitled to on July 11 15th instead of later in the Fall of 2013. She also pushed the meeting time up by two hours and did not want to meet at the AAA office, indicating she would come to the house with a mover to show him what to move and to collect the cars on that day. 39. Since the time of the meeting was changed, Respondent could not be present at her home, so she asked her mother to let Petitioner and the "mover' into the house. 40. Respondent left the three cars' titles for Petitioner on her kitchen table. All of the cars were parked on Respondent's driveway and were waiting for Petitioner to pick them up. 41. While Respondent was at a settlement in her office, she received several calls from her mother stating that Petitioner and the "mover" where going through the entire house, opening every cabinet and taking pictures of all the contents of the house, including many items that were not designated to go to Petitioner under the Settlement Agreement. 42. When Respondent arrived at her house and asked what was going on and why Petitioner and the "mover" were taking the pictures of her personal property, Petitioner stated that the "mover' needed to know what to move. 43. Respondent recognized the face of the "mover", who was not a mover but was actually auctioneer David Cordier. 44. Respondent told Petitioner that before bringing an auctioneer to her house and taking the pictures she needed to have Respondent's approval. 45. Petitioner continued to lie about Mr. Cordier's identity, claiming that he was not the auctioneer, but a mover. 12 46. Petitioner then handed the cars' titles to Mr. Cordier. He asked Respondent for three short certificates, which Respondent provided. 47. Petitioner asked Mr. Cordier if Respondent needed to sign the titles. Cordier answered that they did not need Respondent's signatures. 48. Petitioner said that she would come back to pack the items set forth on Exhibit "A" of the Settlement Agreement on July 14th and subsequently return on July 15th to take possession of her property as spelled out in the Agreement. 49. Respondent felt violated after Petitioner brought an auctioneer to her home, misrepresented him as a mover, and then rifled through Respondent's home and personal belongings. 50. With the help of her neighbors Respondent separated the personal property to go to the Petitioner under the Settlement Agreement, put it in her garage and informed Petitioner that it was there for her to pick up. 51. Respondent went so far as to organize the items by groups representing respective rooms (as the items were organized in Exhibit "A" of the Settlement Agreement), and marked those groups with paper signs on the walls, so that Petitioner could easily compare the items in the garage to the list in Exhibit "A" of the Settlement Agreement. 52. When Petitioner arrived on July 14th, she was upset that she did not have access to the rest of the house. She became rude and indignant. 53. Petitioner stated that she felt she was entitled to additional property, which was not included in the Settlement Agreement. 13 54. Petitioner had come without the Settlement Agreement and did not have the list of the items spelled out in the Settlement Agreement. 55. When Respondent offered her the list from the Settlement Agreement, Petitioner refused to take it, saying that Respondent had wrong list. 56. At that point, in the presence of several witnesses, Petitioner used derogatory terms in reference to Respondent's nationality. 57. Petitioner stated that she would return on July 15th to take possession of her property. 58. At that point Respondent decided that she would not allow Petitioner on her property without a constable present. She retained a constable who called Petitioner on Monday, July 15th, to inform her that he would be present while she retrieved her property from the garage. 59. Petitioner told the constable that she would not show up and stated that she would engage her attorney because she felt she was entitled to more. 60. After this dispute developed, Petitioner briefly retained Attorney Jillian Golden from Rhoads and Sinon, who contacted Respondent on behalf of Petitioner. 61. Respondent informed Ms. Golden that given the actions of Petitioner, Petitioner would have to sign a receipt and release instrument prior to removing any property. 62. Although the remaining check of $14,000 is not due until the closing of the estate, which has not occurred because of this dispute among other reasons, Respondent offered to provide the check to Petitioner provided she signed the receipt 14 and release, removed the property from her garage, and paid for half of the constable fees. 63. Although paragraph 23 e. of Petitioner's Petition states that Respondent is in breach of the Settlement Agreement for "(f)ailing to turn over to (Petitioner) all of the vehicles listed in Paragraph 2(A)(iv) (of the Settlement Agreement), David Cordier eventually returned to Respondent's home with a notary, Respondent signed over the titles to Petitioner, and Cordier removed the vehicles on behalf of Petitioner on December 4, 2013. 64. Paragraph 23 e. of the Petition is therefore patently false and Petitioner violated 18 Pa. C. S. Section 4904 when she signed the verification to the Petition. 65. On Friday, January 17, 2014, Respondent was informed by Attorney Golden that she and Rhoads and Sinon no longer represented Petitioner. 66. Although the personal property to which she is entitled is still in the garage, Petitioner has made no further efforts to retrieve it. Instead, she hired a third attorney who filed this lawsuit with no prior communications with Respondent or counsel for the estate, now claiming that the Settlement Agreement is void. 67. Respondent remains willing and able to reasonably cooperate with Petitioner to deliver the personal property to Petitioner, and Respondent would be delighted to see Petitioner's personal property removed from her garage. 68. Petitioner's Petition is groundless, dilatory, obdurate and vexatious. 69. Petitioner's Petition is in violation of Pa. R. C. P. Rule 1023.1 in that the claims, defenses, and other legal contentions therein are not warranted by existing law 15 or by a nonfrivolous argument for the extension, modification or reversal of existing law or the establishment of new law. 70. Petitioner's Petition is in violation of Pa. R. C. P. Rule 1023.1 in that the factual allegations therein do not have evidentiary support and are in fact directly contradicted by the evidence. 71. Petitioner should be required to pay Respondent's legal fees and costs as a sanction for filing of this groundless action. WHEREFORE, Respondent respectfully requests that Petitioner's Petition be dismissed and that Petitioner be ordered to pay Respondent's reasonable attorneys' fees and costs. Respectfully submitted / Thomas P. Gacki, Esquire (PA I.D. #44864) Eckert Seamans Cherin & Mellott, LLC 213 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: 717-237-6093 Facsimile: 717-237-6019 E-mail: tgacki(a)-eckertseamans.com Date: *brch 2014 Counsel for Respondent, Nataliia Tykhonova Adler 16 VERIFICATION I, Nataliia Tykhonova Adler, hereby verify that foregoing Answer is true and correct to the best of my knowledge, information, and belief. I understand that the statements herein are made subject to the penalties of 18 Pa. C.S.A. §4909 relating to unswom falsification to authorities. /ri y Nataliia TykjiOnova Adler Dated: (LOS47078.1) CERTIFICATE OF SERVICE I hereby certify that on this 7A / ay of 1�, 2014, a true and correct copy of the foregoing ANSWER TO PETITION WITH NEW MATTER was served upon the following via United States First-Class mail, postage prepaid, as follows: Paige McDonald-Matthes, Esquire Obermayer Rebmann 200 Locust Street, Suite 400 Harrisburg, PA 17101 Thomas P. Gacki, Esquire Counsel for Nataliia Tykhonova Adler 22 From: "William L Adler"<BAL @BillAdlerLaw.com>B Subject: FW:Robert Adler Estate Inventory Date: February 24,2014 521:41 PM EST To: "Natasha Adler"<natasha @prudenBalhomesale.com> 1 AttachmenL 3.4 MB Natasha: Here is an email I sent to you, Ron and Stacy on July 2, 2012. The inventory was attached. Bill From:William L Adler[mailto:BAL @Bil]AdlerLaW.com] Sent: Monday,July 02,20121:52 PM To: Natasha Adler(rlatasha @prudentialhomesale.com);Stacy Adler Smith(preppymoml @aol.com);Ronald D.Butler (rdb @ butlerl awfirm.com) Sub)ect:Robert Adler Estate Inventory Dear All: Attached is the inventory with exhibits for the estate with the information that I have currently. Please call me with any questions. Thanks, Bill Law Office of William L. Adler, Esquire 4949 Devonshire Road Harrisburg,PA 17109 Phone:717-652-8989 Fax:717-307-3343 Email:BAL(ta BillAdlerl-aw com Website:Bil(AdlerLaW.com 2012 07 02podf(3.4 Mgt INVENTORY Robert Adler Estate July 2,2012 Prepared by William L. Adler, Esq. Asset Debt Notes Value Integrity Bank Exhibit 1 $156,526.71 certificate of deposit (date of death value) Metro Bank Exhibit 2 $17,840.85 checking account (date of death value) Metro Bank Exhibit 2 $1,611.00 checking account (date of death value) Members V Exhibit 3 $25.00 savings account (date of death value) Members V Exhibit 3 $2,848.88 savings account (date of death value) M&T Bank Exhibit 4 $575.07 checking account (date of death value) M&T Bank Exhibit 4 $11,015.90 checking account (date of death value) M&T Bank Exhibit 4 $11,246.46 savings account (date of death value) Safe deposit box The contents of the inventory box consisted of M&T Bank jewelry listed on Exhibit 5 This jewelry has not been appraised. Personal property See Robert $82,300.00 furniture and cars Ensminger appraisal, Exhibit 6 Smith Barney SEP Exhibit 7 $323,493.08 value as of January 3l, 2012 Page 1 of 3 2930 Arcona Rd. Exhibit 8 $525,000.00 Mechanicsburg PA Appraisal showing value (date of death value) Citimortgage Exhibit 9 ($202,224.76) (Mortgage against mortgage statement 2930 Arcona Rd.) as of April 2012 Fulton Financial Exhibit 11 and 12 Corporation Stock value unknown 4 shares IRA Exhibit 15 $12,024.59 Chip Thrush Value as of June 29, 2012 Firearms Exhibit 16 Value is estimated by Richard Ruble.. No independent appraisal has been obtained. Cigarette Boat Oral offer to $3,000.00 purchase boat from Barry Lefever, 786- 2949 (William Adler has not seen or appraised the boat. From all accounts it is in bad condition.) Checks written as This must be ($46,711.64) estate expenses considered in calculating the net estate. This list is not complete. Total assets minus $898,571.14 mortgage debt and estate bills(estimate as of July 2,2012) Page 2 of 3 OTHER FACTORS TO CONSIDER Informational Not all checks can be $177,013.77 purposes accounted for in that Approximate value in Natasha wrote checks estate checking not recorded in account William Adler check register. Exhibit 10 Rite Aid Corp Equico has been out (owned by Equico of existence for about Realty Group) ten years. 4 shares Value unknown Page 3 of 3 integrity B A N K March 7,2012 William L.Adler Attorney at Law 4949 Devonshire Road Harrisburg PA 17109 Re: [state of Robert A. Adler SSN 210-44-6935 Dear William, Robert A. Adler had been a customer with Integrity Bank since 2009 he had one Certificate of Deposit; the details of the account are as follows: Date opened: September 28,2009 Ownership: Individual DOD balance: $156,526.71 Date Acct was closed: 03152012 Please feel free to cnll 717-920-355 with any questions, Thank you. Sincerely, �t J Cheryl D'Sou7w Assistant Mann_eer Integrity Bank ,/3l5.tLrrrr Snrrr.Cnn)Hill IW /:Oil•lbnnr.•:1''J!O J?00•d: /Nal'Elr•fnn'/:-9!O y'lO!•t^. METRO BANK( ,! 3801 Paxton Street 838.937.0304 i V K Harrisburg,PA 17111 mymetrobank.com March 9,2012 William L Adler 4949 Devonshire Rd Harrisburg PA 17109 RE: Estate Of:Robert A.Adler Tax Identification Number:210.44.6535 Date of Death:January 25,2012 To Whom it May concern: This letter is in reference to decedent account information you requested for the individual listed above. We are able to provide the following: Account Type:Checking Account Number.538200593 date Opened:9/22108 Date Closed:3/2112 Primary Owner:Robert A.Adler Date of Death Balance:517840.85 Account Type:Checking Account Number:538200759 Date Opened:9%22/OS Date Closed:3/2/12 Primary Owner.Robert A.Adler Date of Death Balance:$1611.00 Please feel free to contact me at(717(412-6122 111 may be of further assistance. Sincerely, Diana Reynolds Metro Bank Support Assoclate/Deposit Services —z_ §a MEMBERS 1"J rn1EnALCmn MILS SAVINGS ACCOUNT: Account Number/Suffix 177970.00 Date Account Established 08/12/1998 Principal Balance at Date of Death $25.00 Accrued Interest to Dale of Death S.00 Total Principal.and Accrued Interest 525.00 Name of Joiril'Owner None INVESTMENT SAVINGS ACCOUNT: Account Number/Suffix 177970.05 Date Account Established 02212006 Principal Balance at Date of Death $2,848.44. Accrued Interest to Date of Death S.44 Total Principal and Accrued Interest 52,848._88 Name of Joint Owher None M ERS IT FEDERAL CREDIT UNION banielle Iine Lending Insurance Support Specialist March 8, 2012 Estate of: ROBERT A.ADLER Date of Death:02120/2012 Social Security Number.210-44-6935 50DO Lnukc Dricc R0. lynx Orr \Icchanicslmrg, l unnscicanin I-705; (51111)283-15211 Ic«nv:mcmbcrslsr.org — ,. ,: q, � _ ,! ^.tt w. i iv � .. � .. w' �' U � . �� ^ : ' ... � �• t 2 rypeojAtttaot� SadWAmmoa Avexw t5Ap4276706662 01*WJdp(1Vmw4o . RobarAAdler opoftDm MOW Rak=mDataj;rDbmd $114" Aa+aeni& .17 Hurd Patasl nC3iMmm111mfmgxa6awaomaaty.4�dadt�atlP�o�1`d�ooSnrala�m+Varimtattandq . pTamavD9roR3��aSbedaYtYfAliF130t {�QIIC IaOa�Ital0�oa0leal(�{gICdG�{�lpalaCQlOa�fgYaa1071d01q�dl�tq�. rrvaaaeraaesam6u OVavaaMm Oft 00&DOWawrybmbwuStlaAaftmofA#mq.Qatftd tWp=7WMk% @IlfplagarRY��W dSa Will�dl/lplam�G SlMdy. valadem= 04/1212812 15:46 7177834447 PA DEPT_0. 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S-RL-ZADORESS A / � Oft -STATA: ZIP COOS: c NAME-- REtAT10I15HIP: ET.LrrACDRESS: CRY: SATE ZIPCOCE: HANEAND ADORESS OF FCMMAANCIAL`RISTNITION MERE THE SAFE DEPOSIT DOX IS LOCATED NA/12 T STR.17AOCRESS: CRY: ATE: WOODS: 7119 97 ir C4,D ff 7 • HAM OF PERSGJ1 UAlO 0 ENTRY DATER DTI EOFLASENTRY P� !8 "L- DATEOFCO CTTO REM SOX NUUBEROFUDX I TOLE UNDER BOX TS REDO Z/b Q6 Re6crP c' RAKE AND ADDRESS OF PERSOn SI HAVING ACC 25 TO BOX b. A.UL 5RL�ET_ AD�FSS, SMEETAOCRESS: AP CCO p CITY. STATE: ZIP COOS `7P G S 1705 NA3E ANO TIRE OP QPLO T )NO TIE ItrvgY70M1Y [Fj It'laevnuMTHE ozT ❑ YES CrRG a Ao, noaemwvi: b. Huse And Addm t of FDDoAAI mpnoonlbtM,It tined In 1bo w111 MAIL STREETAD)ORESS: CITY. SATE ZIP CODE: e ehnn oatl Addmoo of Aoomay,it w A/ OTRScTAOUAESA .Ernr STATE: ZIP DOE L 48500041046 43500041046 84/12/2812 15:46 7177834447 PA D K—W PZ994 E PAGE 85/85 REV40UK SAFE DEPOSIT BOX INVENTORY Pop If 7i INSTRU ONS (t) Oqc Ropaf wW amyr. 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Wit 09PMW MM WYEFf CRVI nmurvae .,mv xo oocoaorr NOxmllt♦a DmIGmM amc $esemamweas. ptsae.rvnunnaaea NOTE:Attach additional BV x 11'Aeolis)If necessary or sae duplicates of eft page of terra. Tnsn mtraab edeamal hrtu Q fmlWf1R719.mnabed6ekawdsaddiogtlUrua>aebaaee1,mama�amtstlao�St�erenen ot�paaWn�peaa¢head 1��o anor ebumastYd>Aimlm deabourancPoemi4 I- j i y � f f t . 1 i i �. t 1 l t { } i It S { I 1 �, _. � � _ } i x lit, pai 5T S� z s . 3 rao 7PIAVI Pp 4f Ills -7 Oc . 7 rO , - 1 i i j R ROBERT ENSMINGER APPRAISERS REAL ESTATE n77d PERSONAE PROPERTY 3557 -Imenon Avenue June 27, 2012 1tacrisburg PA 17109.113? Mr.William L. Adler, Esquire 717.6524111 voice 4949 Devonshire Road 717.370.5777 Fax 717.977.735n cell Harrisburg, PA 17109 I�t[mm nacommmnel at RE: Estate of Robert Adler rw rn, " flFLSIl1F! nuu•.F.ncmin t .ne Dear Mr.Adler. In accordance with your request, I have appraised the personal property of Robert Adler, Deceased. The property is located at 2930 Arcona Road, Mechanicsburg, PA 17055. 1 have made a physical inspection of the items listed in the attached report on May 17, 2012. The values shown have been arrived at after a careful study of the property. I believe it to reflect a true measure of its estimated value as of February 22, 2012. You, as executor, are the intended user of this report. There are no other intended users. The intended use of this report is for estate purposes. Estimated value is defined as the appraisers professional opinion of the estimated gross amount, expressed in terms of cash, which the listed assets would typically realize if exposed for public sale at a property advertised and professionally managed orderly liquidation at a listed or negotiated price usually within a short period of time of the effective date of this report. Further consideration is given to the ability of the assets to draw sufficient prospective buyers to insure competitive offers are considered. All items are valued on a per item basis, in "as is" condition, with purchasers responsible for removal of assets at their own risks and expenses. Any deletions or additions to the total package could change the psychological and/or monetary appeal necessary to gain the price indicated. Taking into account all of the factors set forth in the pages that follow, it is the opinion of the undersigned that the estimated value of the listed personal property is Eighty-Two Thousand Three Hundred Dollars ($82,300.00.) Employment in and compensation for making this appraisal are in no manner contingent upon the value reported and I certify that I have no financial interest in the property appraised, present or contemplated. Very truly yours, Robert A. Ensrninger ITEM VALUE 2008 Dodge Charger SRT 8, Super Bee, 40,380 miles, s/n 283LA73W20HI71795 $ 24 800.00 2004 Hummer H2, 52715 Miles, deluxe, On SG G 3U 5 $ 21,000.00 2000 Corvette Convertible s n lGlYY32GOY103806 $ 22,500.00 1978 Chevrolet Camaro, Z-28, 79000 miles, not running $ 1,000.00 1988 Chev Blazer Sllverado Rough condition $ 300.00 Kindal dresser $ 250.00 Bench $ 50.00 2 cabinets $ 200.00 Sofa table $ 200.00 Mirrors $ 300.00 Henderson sofas $ 700.00 Glass coffee table $ 250.00 Elephant table $ 250.00 Black wing chairs &ottomans $ 300.00 Leather top end tables $ 150.00 Dinina table &6 chairs $ 900.00 Pedestal table $ 450.00 Magazine stand $ 40.00 4 leather chairs $ 600.00 Round glass table &2 chairs $ 400.00 2 vinyl benches $ 200.00 Bar $ 200.00 Glass end tables $ 150.00 2 night stands $ 200.00 King size bed $ 600.00 Dresser $ 400.00 2 chairs $ 150.00 Desk $ 75.00 Chair $ 125.00 Chest on chest of drawers $ 350.00 Table $ 75.00 Lowboy chest of drawers $ 300.00 Bedroom suite, 2 single beds, chest of drawers, dresser, night stand $ 800.00 Wicker chair $ 125.00 Sony TV $ 200.00 Leather sofa $ 600.00 Coffee table $ 100.00 Glass table $ 100.00 Side chairs $ 50.00 Wine rack $ 75.00 Sony projection TV (large screen $ 250.00 Desk &chair $ 75.00 Sofa &chair $ 100.00 Sofa $ 50.00 Coffee table broken glass 35.00 Double bed night stand &dresser $ 225.00 Sliver plate Reed & Barton 10° bowl $ 30.00 S.P. butter tray $ 10.00 S.P. Reed &Barton tea service 100.00 Sterling basket $ 200.00 S.P. Sheffield meat elatter $ 50.00 S.P. Sheffield tray $ 35.00 S.P. Sheffield plate 25.00 Sterling vase (weighted) $ 100.00 6 sterling forks 5 butter knives 6 dinner knives $ 325.00 Danish stainless steel Flatware, service for 6, 6 serving pieces $ 125.00 Copper kettle $. 200.00 Large crVstal vase $ 100.00 Large crystal bowl $ 125.00 Crystal basket oval $ 125.00 Large deer sculpture $ 500.00 TOTAL 82,300.00 ) � ) ! § qmq ■ , RRRq . ; . g § R : I! ! k°° k # ■ = fLk q ® k fE .7 � IJ ] . �| ! & | c k ! §/ kl � /] 2 k la | �. in E� ; 2k kk § ;2k ) e � ' ■ ° �« ¢ r §}\, � � $ ) 2 � k ° o ? �! ® 2 ' _ , _� -a � � § ® % I77 ; US k �� £ ! ! � \ £ Bkk�k uew . e � <a a .zz , r � . n 7 n 2 ® - 2 , ■ F . ! i¢ . � . A k � 2 § LA Lon § § ( Ci sue§ § ' £ cc % I§Ca 3 { k28cc §2§§§ CL » kuj L\_ / k i - -o�•_ _ § § | ! k¢uR■ § p § § - $ I / ! ! § 2 ® © ! | ! � ttt ! = k& 2 } k . RESIDENTIAL APPRAISAL SUMMARY REPORT Rallis: ARCOWD2930 COST APPRDACH TOVALUE devdote ]O Tk Cut Anastasia ls2S lla emdeoed for this=aaluL Pmidt MMML°W01M. �M fa 1e01:8a1CIt fallmiv M,hares and catolLtcj. 'Sup;,:,to Oe ap5dm c:sbJ s71ua IsummY d caTSe11t Lnd aa�s a air mr9a';it:ib.TaLi;s.:sglut): 1ESTIM,17LD REFRODUTITIOR F-'F_=AACELSUT COST IlEV! no v SOr-a coil datl: U'hclll'3 Solt.a)S _—=S o DL1lY r.,ino train cast a,•.'.2: 61ettve dse at ccsl dsra' I S A.('S _=c a Cunt'm Coil Appaa:h(9m55 fnirg sea cezulslma.e:,.'e:iadm,v4.): CgFI.ra S =e Eq.FI.On< -s w Sc.FL 0 =s U WngYCartn Soil.(v5 =S Final EsE7,•.all Ca;l;ttw _ =S Less Pml.a Ih onel IEdcat jn DeoreJa:m =SI Demttluc7 Cc;l al h9m:mer3 =S 2.Y.F Si1:ITJ:CetaCri =S =S =S Esw�'S RcraTiro Etaedt Lilt fd rwJrdl: 1's Ie101:ATEDVALUEBY COST APPROAdI___..._.____ =L � WTASI APPADACH TD VALUE fildneto .dl NTre lxcaE Anxmch ns r:d'.f-:03id lot urs=]slIse. e Ez m"I.-WHY M?A--:RadS a axis Ilm l.Yti L =5 hit:aled Vafr h:maA =cA cSunni d Imme Approach limcluSrg support for mad*_!rent=d ORId): 5 c to f O n z_ PR DIECTOfFORMATIO UFOR PUDslifaooliable ITre soml b oar,C r Paned Um DC'..cmed. C nV I'm Of From= N-1Y.coon aU.Ta[;and Rxubaal fiacaf: n hJ!aled Yalueb.ices Cam adson Aa;mmh5525.000 Cost Aopma:h(it developed)5 hoome Ammach Dfdevelooedl5 kaiRY7.dlaam See anachotl addenda. z 0 7 This aP;s2l3a Ls mane L'-ZS is". 1_ s:n;td to Cor;er:-ps plans n-d T:v :Catac m he os6 d a P."W'r'izo Card.:m In m il�alls"s hate heel caTg`.J. ]sN ac ve loke!.q melts a to,almj ea OE bassi d a kp]2tial Cord.cn Vial Ire r!DDs o:i_a',ms rase t-n cam, :J,i II vjb±:I W Ej D Ve f3IV V(¢Tired L^.ip—Lm b3N a1 ite EEraadT:.Y AVIrladCil thi Ve WY:t]l at MICi::Y ones no!rtQUie =lmn G.fQah: 0 W C a THi r'O]d Is d'aq std t 10 oms lhncdevral CcGt_ a.•s:.'ce Enlaced.l'AS3gTatgni as sne:ified I.,Le aMW.addcllt - - Sued on the degree of lnspecllon of the subject property,as initiated beSw,defined S:opt of Vlork Stzltmcnt of Assumptions and Um1Ung Conditions, and Appralsets Certifications,my love)Opinlon of the Varkol Value(or*In--specified value type6 as defined herein,of the real property that Is the subject of this report IV S 525,000 mot: 03202012 ,rihich Is the eliMive date of this epppMost. It Indicated aboro,this Opinion of Value is subkgt It flppolhNal Corel end/or Eclmo7nvy Ascumpilons in:luded in this report. See z=;hed ealdenda. A M a:d Curmiffe con of pits HOW mrl!ns 17 pE.s.iniaiap eviq}n`:h se Cgrsdim an mgm pal of hi renod.Tits Epp:z'sU rgpq my not be see pnpctj cs,erVood w;T:x ideation I]Le V'onraim con.�tJ h the cc.T'3 report i A=zd E]."Nuc C Scope a Work E.Uniho Conl.rn,"a:C:a IJ vzt=a.,9m:fm I'-,picuDg aph Atd!ida `.'Sir--h AAJYJwn ¢ r h'ap Addenda rAadcnal SES 0 CD31 A!.'+.Y¢n I f Ithw2a i--al Cend:cti I iEcaC:dinav A;r ca n;ae eCrMatm -1 P.1 Leo 6 Sreran•Pal, :z,�orT LHSLa��o.T 'Cf=Cutace Ci!taam: Natasha Adler E-IhT A^.::ass: 2930 Aron Rd,IA-chaninsoung PA 17055 APPRAISER SUPERVISORY APPRAISER(if required) F or CO-APPRAISER(If applicable) S JoMS S., Spl9NSC�'a Co-App:a'ss IiaTe C7 Ccrn)ity Central Penn Anmatsais In, CcnaaR N Pati' (7171737-1600 Far 57171737-9123 Firm ins E-L':3 ioMrahnnapomisers.om E-L'a[ Dse O:RW(S1pVre): ¢1112o12 Dale of Repel(54ut¢et UMT!Ct Ce;ACiLm O: RLOO1405L Smic: PA Worse a Cua—I im Ar: osL.`eT oeslgna= Ep2m Da'.of License of CerfIrMOM 06.1302013 Ep6alim Dar of UCCae at Cer ifi;r= n=150q of Stb)xt 3K Irvma&Enmu ❑ECmx O.!/ IJ Me! LW-0011 d S--bet ❑lrtn7 6 U15ia J E D-+•01las On 03292012 Date d lmott:-¢ mRESIDENTIAL gyQOagarysp z.tcR lxncxt rss¢1 r.=slaampmac,bmr,IO c_.rcn Faml GPRF52—'ALITf1TAl'TppT.HEI sg6,rae bj a la mot_Irc.-1-�OAIAIAODE Statement Date: 04/17112 - pve I of 1 ;�V Properly Address:3M ARCONA RD RECHA7dICSBURG PA 17C955 a CItIMG(t9dG? ACCGJPR NUMBER:0.X,53 1522:83 `.Customer service 1.804153-7918' ,�;; P7ease rztxence ya:a ac,^.,unl morded OJ:n115239 when celEng, °• Tyy at MCngage FIXED RA—it LC.5r-0 � ,�:�e`'" 'L�S a;2 r1�m1J^ar.�ca�drea.4sd v.t._z c+a6}�'�, Primal Balance 527222.'75 Imere;l Rate 4.5757CX 'es_—rr Balance 55,817.22 0165,3103 13Z 1o5 51SW 710 A.Ml Joe Interest Year Taxes Paid Yew to Date s eei . ih111111d�11lghtldt�lr'1111111g111'd111111'hrdu'�14t -= ROBERT A ADLER 2930 ARCONA RD MECHANICSBURG PA 17055-5901 PAYRIENTS CURRENT , RECEIVED PAYMENT DUE ZE Date O50112 �g Frm#al 5:53:$ r3 Interest 5819.72 �? =3 Esc 5810.19 VytuSalrmxdtinor_one.com! iota)Mortgage Payment S2.•LuN329 r,,.: _ Late Charge 563.50 Past Due Amount 4M4.08 CitMorolane om is m soure for the latest interest Ile,and ruluable tools for reinancng TatalAmount 5421409 or purchasinganew ho;ne! Yad dlim;.",aaoe mm tec.'+y. Your payment was not reccatred by stalernern date. late charge of So3aD was added on 04116112 PI a sand total amount dr. 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PA 1705S.S937 ____.._.__...__—....--_...___.... .._ .... _...coot .. .._ _. _. ...... ISymbol Available TOIeI HAV Avellabl0 Total Nome Shares She," Price Valuo Valm AOnVX 0.000 0.000 $9.36 50.00 50.001 I4etr=U.S.Gevemmard Fold-C/dU A _ PAX 1,147.385 1.147.305 510.48 $12.024.59 5eSOO Can anw6 w Albeo6on Clew A..-0000 .000 570.32 SO.00 SOM s3o0 VIE Asael Altxyp'pT Cw Fd A Toml Allwarlgl Vofm os of ON alwk 572.07A.59 S12.02C59 ... ... _..count._._.. ..__.._. .._ 'Click a symbol for ecwunl statement. 1 https://prime6ca-impress-net.com/secure/holdings.asp 7/212012 E m .. c a o CU y c v u E r_E 0 E U = u u E 3 'O u = y x •t Vin E w .00 Lnn Lnn m m z 0 0 0 0 0 0 0 0 Idi f_E o 0 o O o 0 0 0 y m N m n n m O l!J 07 IT .� m ti .a .-� M N O O O GL l O O O O m O O O y O O Ln O O ++ '-' O O O O In t^D m Z m ti (1 Q LD CL en ti. yr yr tfr yr try v+ N m L cn m Y C2 Ln f�'6 3 pCj c M C71 7 Ru CL y U 'D n to cn N N In co L E 0) Q O M O N N tD (n 7 T vNi n W W N N '•I Z N m >- N m 0_ a m M d u N N n C N a ¢ N M m N N m V O E O N 0) N m N m t0 O L 7 N m C H i 0 (n = n aJ = I" 1 0 C vI to n V' m = U jR U "y c v m 3 :3 d IL N m z c 0 u m Cl) O j > co r o v o 0 0 L. a v ¢ a >ci m a 0 n. f� E E 0> > E m E In c Lnn u_ a in n0. LL O O O ^ 7 N atd � a N m �7 C7 v u u m > .� U" u° u 0 m o CERTIFICATE OF SERVICE I hereby certify that on this 1 Zday of March, 2014, a true and correct copy of the foregoing ANSWER TO COMPLAINT WITH NEW MATTER was served upon the following via United States First-Class mail, postage prepaid, as follows: Paige McDonald-Matthes, Esquire Obermayer Rebmann 200 Locust Street, Suite 400 Harrisburg, PA 17101 Th as P. Gacki, Esquire Counsel for Nataliia Tykhonova Adler 22 i.