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IN RE: : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA,
ESTATE OF CLAIRE WONG CREGO, : ORPHANS COURT DIVISION
AN INCAPACITATE PERSON :
: rvo. � /_ j ( _ � 05-�
PETITION TO AUTHORIZE CREATION AND FUNDING OF A SPECIAL NEEDS TRUST
FOR CLAIRE WONG CREGO
AND NOW, comes Petitioner, Claire Wong Crego, by and through her Guardian,
Christine Dixon, by and through their attorneys, Wix, Wenger & Weidner, and files this
Petition to Authorize Creation and Funding of a Special Needs Trust for Claire Wong
Crego, stating as follows:
1. Claire Wong Crego ("Claire") was adjudicated an incapacitated person and
Christine Dixon ("Petitioner") was appointed #he plenary guardian of her estate and person
by Decree dated February 21, 2006, docketed to Case No. 21-06-0056.
2. Claire was born an February 27, 1987, is 26 years of age, has never been
married and has no issue, and resides at 149 West Louther Street, Carlisle, Cumberland
County, Pennsylvania 17013.
3. Janet B. Crego died on December 25, 2005. During her lifetime, Janet M.
Crego established the Janet B. Crego Five Year Trust Dated October 17, 1997 (the "Crego
Trust").
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4. Pursuant to the dispositive provisions set forth in Article Seventh,
subparagraph B of the Crego Trust, Claire is entitled to a one-third ('/3) interest in finrenty-
five percent (25%) of the Trust estate at the time of Janet B. Crego's death.
5. On December 16, 2013, Petitioner executed a Partial Disclaimer of Claire
Wong Crego disclaiming Claire's interest in the Crego Trust in all but Forty-Seven
Thousand Dollars ($47,000). A copy of the Partial Disclaimer is attached as Exhibit "A."
6. By this Petition, Petitioner seeks to obtain approval for the creation and
funding of a Special Needs Trust for Claire under 42 U.S.C. § 1396p(d)(4)(a), with
Geoffrey B. Crego as the trustee of said Trust. Geoffrey B. Crego's Consent to serve as
Trustee is attached as Exhibit "B". Pursuant to 20 Pa. C.S.A. § 5536(b), this Court may
approve the creation of a trust for an Incapacitated Person.
7. Claire has no other assets other than the amount from the Crego Trust noted
above, and her only income consists of$974.00 monthly from SSI and $3,784.00 from
employment with the S. Wilson Pollock Center for Industrial Training.
8. Clare qualifies for and relies upon Medicaid for all of her medical care.
9. Petitioner has attached hereto a form of trust agreement, titled "The Claire
Wong Crego Special Needs Trust," (the "Special Needs Trust") the terms of which are in
accordance with 42 U.S.C. § 1396p(d)(4)(a) which exempts the assets held in Trust from
being considered in the determination of Claire's eligibility for, or amount of, medical
benefits under a State Plan under the Social Security Act, 42 U.S.C. § 1382(c)(a)(3).
10. Because the Special Needs Trust will contain all of Claire's assets, there is
no need for the Guardian to post additional security.
11. Pursuant to the Special Needs Trust, Geoffrey B. Crego shall serve as the
trustee of the Special Needs Trust, with Petitioner Guardian to serve as successor trustee.
12. Petitioner respectFully requests authorization for Geoffrey B. Crego to receive
the balance of$47,000.00 in the capacity of trustee of the Special Needs Trust.
13. The primary purpose of the Special Needs Trust is to provide for fund
handling, fiscal management, investment and disbursement, personal services, asset
protection, advocacy, social and occupational development services, rehabilitation, care,
management and guidance for Claire.
14. Under 42 U.S.C. § 1396p(d)(4)(a), Claire will remain eligible for Medicaid
benefits. Upon her death however, the Trustee will be required to reimburse the
Commonwealth of Pennsylvania for all Medicaid payments made on behalf of Claire during
her lifetime.
15. By letter dated February , Petitioner provided notice of the filing of this
Petition, along with a copy of the Petition and the Special Needs Trust, to the following:
Special Needs Trust Depository
Attention: P Manager, TPL Section
Post Office Box 8486
Harrisburg, PA 17105
SSI Program Support Team
Attention: Team Leader
Mid-Atlantic Program Service Center
3rd and Spring Garden Streets
Philadelphia, PA 19101
[SIGNATURE PAGE FOLLOWS]
WHEREFORE, Petitioner respectfully requests that this Court enter the proposed
Decree attached hereto.
Respectfully S bmitted,
WIX, WEN ER &WEIDNER
�
Date: By:
�.�2��� 4. Stewen C. Wilds, Esquire
I.q: No.: 41692
508 North Second Street
Post Office Box 845
Harrisburg, PA 17108-0845
(717) 234-4182
VERIFICATION
I, Christine Dixon, Petitioner in the foregoing Petition to Authorize Creation and
Funding of a Special Needs Trust for Claire Wong Crego, have read the said Petition
and hereby affirm and verify that it is true and correct to the best of my personal
knowledge, information and belief. I verify that all of the statements made in the
foregoing are true and correct and that false statements made therein may subject me
to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to
authorities.
�" � �.
Date: � c�)
C istine Dixon '
EXHIBIT A
SPECIAL NEEDS TRUST
This Declaration of Trust (the "TrusY') is established by Order dated
, 2014 ("Order") of the Orphans' Court Division of the Court of
Common Pleas of Cumberland County, Pennsylvania, for the sole benefit of Claire
Wong Crego ("Claire"), an incapacitated adult born February 27, 1987, who is a
disabled individual as defined in Title XVI of the Social Security Act (the "Act"), 42
U.S.C. §1382(c)(a)(3). A copy of the Order is attached hereto.
This Trust, which shall be known as the "Claire Wong Crego Special Needs
Trust," is established in accordance with a provision of the Title XIX of the Act,
specifically 42 U.S.C. §1396p(d)(4)(A), as amended by the Omnibus Budget
Reconciliation Act of 1993 (and any federal ar state regulations or other rules
promulgated pursuant to that provision) which exempts the assets held in Trust from
being considered in the determination of Claire's eligibility for, or amount of, medical
benefits under a State Plan under the Act, and therefore, the property directed to this
Trust shall in no way be deemed to have been or to be available to Claire. The
Commonwealth of Pennsylvania, Department of Public Welfare, or any successor
agency, and/or any other state which has provided Claire with medical care under a
state medical assistance program during the term of this Trust, is deemed to be a party-
in-interest herein and therefore shall be provided with notice of any court proceedings
involving this Trust.
Upon funding, the trustee shall provide a copy of this Trust to:
Special Needs Trust Depository
Attention: P Manager, TPL Section
Post Office Box 8486
Harrisburg, PA 17105
SSI Program Support Team
Attention: Team Leader
Mid-Atlantic Program Service Center
3�d and Spring Garden Streets
Philadelphia, PA 19101
Geoffrey B. Crego shall serve hereunder as trustee and hold the sums
distributable to Claire in settlement of the matter known as
, Court of Common Pleas, Cumberland County, No.
, in accordance with the said Order, and any other property acceptable to the
trustee which is added to this Trust, and shall manage, invest or reinvest said property,
shall collect the income therefrom and shall distribute the net income and principal in
accordance with the following provisions:
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FIRST: Distributions.
A. Upon funding, trustee shall use trust principal to fund promptly
an irrevocable burial account for Claire in an amount not to exceed the limits
established by law.
B. During Claire's lifetime, the trustee shall distribute for Claire's
benefit such parts or all or none of the net income (as defined in the Item SECOND
below) and principal as the trustee shall determine in the trustee's sole discretion,
subject to the provisions regarding Trustee Discretion below, for the special needs of
Claire; provided, however, that the trustee shall obtain approval from the Orphans'
Court Division for any such decision to distribute Trust principal. Any income which is
not distributed shall be accumulated and may be, but is not required to be, added to
principal.
C. Upon Claire's death (or the earlier termination of this Trust
under the Administrative Provisions below), the trustee shall pay to the Commonwealth
of Pennsylvania, Department of Public Welfare, or any successor agency, and/or any
other state which has provided Claire with medical care under a state medical
assistance program, an amount which is equal to the lesser of the amount paid to or on
behalf of Claire under by such plan or plans until her death or earlier termination of this
Trust (as finally determined by such state or states), or the balance remaining in the
Trust, in accordance with 42 U.S.C. §1396p(d)(4)(A) and the balance remaining in the
Trust is insufficient to pay each of those states in full, reimbursement shall be made pro
rata among such states.
D. The trust shall terminate upon Claire's death (if not earlier
terminated under the Administrative Provisions below) and the trustee shall distribute
any principal and income remaining in the Trust, after the distribution directed in
paragraph C of this Item, the trustee shall distribute any unappointed principal and
income equally to Meghan Crego and Adam Crego free of trust.
SECOND: Definition of Income. For all purposes of trust administration
hereunder:
A. The term "income" as used herein shall mean an annual amount
(also referred to in this Item as the "unitrust" amount) equal to the greater of (i) trust
accounting income, or (ii) four percent (4%) of the net fair market value of the trust's
assets, whether such assets would be considered income or principal, averaged over
the lesser of (a) the three preceding years of trust administration, or (b) the period
during which the trust has been in existence.
B. The trustee may, in the trustee's discretion, from time to time
determine all of the following:
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(1) The provisions for prorating a unitrust amount for a short
year in which Claire's right to payments commences and ceases.
(2) The effect of other payments from or contributions to the
trust on the trust's valuation.
(3) The frequency of distributions of the unitrust amount
during the year.
(4) Whether to value the trust's assets annually or more
frequently.
(5) What valuation dates to use.
(6) How frequently to value non-liquid assets and whether to
estimate their value.
(7) Whether to omit from the calculation trust property
occupied or possessed by a beneficiary.
(8) Any other matters necessary for the proper calculations
of the unitrust amount and functioning of the trust.
C. Claire will likely to be required to include in her gross income
for tax purposes all the taxable income earned by this trust during her lifetime (including
realized capital gains), to report such income on her personal income tax return, and to
pay the income tax due with respect to such income, because this trust is a "grantor
trust" under the Internal Revenue Code of 1986, as amended. To the extent that Claire
is required to include in her taxable income any portion of the income earned by this
Trust and pay the income tax due with respect to such income, the trustee shall pay to
Claire, the guardian of her estate, or to the tax authorities, from principal, without further
court approval, an amount equal to the increase in income taxes, interest and penalties
thereon, payable because of such inclusion. After Claire's death, income taxes shall be
paid by the beneficiary and/or trustee under ordinary fiduciary income tax rules.
THIRD: Trustee Discretion. The trustee shall be guided by the following
when exercising discretion hereunder.
A. Wherever the trustee has the discretion to determine whether or
to what extent principal or income shall be distributed to be used for the benefit of Claire
hereunder, the trustee shall consider the resources and sources of funds available to
Claire through any state or federal public assistance program. In making this
determination, the trustee shall consider that the purpose of this Trust is not to supplant
public assistance benefits, but to supplement those benefits by providing only for
Claire's special needs, in such manner that Claire will not be disqualified from any local,
state or federal benefits.
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B. The term "special needs" refers to the maintenance of Claire's
good health, safety and welfare when, in the discretion of the trustee, such needs are
not provided, or not provided in a timely or desirable manner, by any public assistance
agency or other public or private source. Such needs may include, but are not limited
to, extra and supplemental medical and dental care, physical and mental health care,
nursing and custodial care, vocational and other training, case management and
guardianship fees, equipment and supplies, therapies, nutrition, transportation,
maintenance, education, therapeutic travel and recreation, and the like.
FOURTH: Protective Provisions. This is a discretionary, non-support trust. No
principal or income of the Trust shall be anticipated, assigned, or encumbered. The
Trust shall not be liable for any debt, contract or engagement of Claire nor subject to
any legal process. No part of this Trust estate shall be construed as being subject to
the claims of Claire's voluntary or involuntary creditors. The trustee shall deny any
requests by any public or private entity to disburse Trust funds for support or other care
that such entity has the obligation to provide to Claire.
FIFTH: Debts, Taxes and Expenses after the Death of the Beneficiarv.
A. Upon Claire's death, the trustee may thereafter in the sole
discretion of the trustee and without court approval, pay the following expenses from the
principal and/or income of the trust prior to repayment provided under Item FIRST: C.
above:
(1) All taxes and any interest and penalties thereon due from the
trust to the State or Federal Government because of Claire's
death.
(2) All reasonable fees for administration and/or termination of
the trust estate, such as preparing and filing and accounting
of the trust with a court.
B. Upon Claire's death, subject first to repayment provided
under Item FIRST: C. above, the trustee may thereafter, in the sole discretion of the
trustee and without court approval, pay any part or all of the following from the
remaining principal and/or income of this Trust.
(1) The outstanding debts and expenses of the Trust to the
extent not already paid under Paragraph A above.
(2) Claire's debts, funeral expenses, and expenses of the
administration of her estate, if Claire's testamentary estate,
exclusive of her residence and tangible personal property,
shall be insufficient to pay such debts and expenses, but
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none of said debts or expenses shail be enforceable against
the trustee by reason of this provision.
(3) Such taxes, and interest and penalties thereon, on the
balance of Claire's gross estate for tax purposes as the
trustee may determine to be appropriate in order to facilitate
the settlement of Claire's estate, but none of the said taxes,
interest and penalties shall be enforceable against the Trust
by reason of this provision. No beneficiary shall be required
to refund any part of such taxes, interest or penalties.
SIXTH: Fiduciarv Powers. The trustee shall have the following powers, in
addition to any powers given the trustee by law which, anything to the contrary herein
notwithstanding, the trustee may exercise in the sole discretion of the trustee and
without court approval unless otherwise specifically provided in this Item:
A. To retain and invest in all forms of real and personal property
in accordance with and as authorized by the Prudent Investor Rule, 20 Pa. C.S.A.
§7201, et seq., as amended from time to time, including any real property used as a
residence suitable for Claire's needs, notwithstanding the fact that it may be non-income
producing, provided that any such real estate investment must be approved by the
Orphan's Court Division.
B. To join in any merger, consolidation, reorganization, voting
trust plan or similar action, and to delegate discretionary powers or duties with respect
thereto.
C. To sell at public or private sale for cash or credit, to
exchange, or to lease for any period of time, any real or personal property, to give
options for sales, exchanges or leases and to allocate premiums from the sale of
options to income or principal.
D. To take any and all action which the fiduciary deems
necessary to prevent, abate, "clean up" or otherwise respond to any actual or potential
violation of any federal, state or local law, rule or ordinance affecting any property held
in this Trust related to the generation, use, treatment, storage, disposal, release,
discharge of, or contamination by, any materials or substances that are prohibited or
regulated by federal, state or local law or that pose a hazard to the environment or
human health, and to charge the expense thereof to principal or to income or partly to
each (provided, however, that the trustee shall obtain approval of the Orphans' Court
Division for any such charge to principal).
E. To borrow money from anyone, including a trustee
hereunder and to mortgage or pledge any assets as security therefore.
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F. To compromise or settle ciaims without obtaining any
beneficiary's consent.
G. To make distribution in kind and to cause any share to be
composed of cash, property or undivided fractional shares in property different in kind
from any other share, giving consideration to such extent as the trustee determines to
the federal income tax basis of such property.
H. To allocate all structured settlement payments or annuity
payments to income unless otherwise specifically directed by the Orphans' Court
Division.
I. To apply any payment of income or principal to which Claire
is entitled hereunder directly for her benefit or to pay it to her natural guardian or legally
appointed conservator or guardian of the estate or person or such other person as the
trustee elects to disburse it for Claire's benefit. The receipt of the person so selected
shall be a complete discharge of the trustee therefore.
J. To repair and maintain any real personal property and to
charge the expense to income or principal (provided, however, that the trustee shall
obtain approval of the Orphan's Court Division for any such charge to principal).
K. To determine whether any receipt or any portion thereof
including premiums from the sale of options, and any corporate distribution which is
described or designated by the corporation as a stock divided or as a distribution that
may be received in cash or in shares of the corporation at the option of the holder,
should be charged or credited to income or to principal where the allocation is not
clearly prescribed by governing law, and expressly may allocate short term capital gains
to income or principal regardless of governing law. Notwithstanding the foregoing, no
trustee who is a beneficiary shall participate in deciding whether short-term capital gains
may be allocated to principal or income.
L. To arrange for the services of any public or private
organization established to assist disabled persons, to monitor a beneficiary's living
conditions, evaluate his or her needs, determine whether a given distribution to Claire is
for her special needs, and identify available social, financial, developmental, or other
programs, without diminution of compensation otherwise property payable to the trustee
and to charge the expense thereof either to principal or to income partly to each
(provided, however, that the trustee shall obtain approval of the Orphans' Court Division
for any such charge to principal), without liability for any act or omission of any such
individual or organization or for any act or omission made in reliance on the advice of
such individual or organization, provided such person or organization was retained with
reasonable care and prudence.
M. To retain legal or professional assistance outside the
expertise of the trustee in establishing, maintaining, defending, administering and
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_ __ _ _ ___
terminating this Trust and accomplishing its purpose, without diminution of
compensation otherwise property payable to the trustee and to charge the expense
thereof either to principal or to income or partly to each (provided, however, that the
trustee shall obtain approval of the Orphans' Court Division for any such charge to
principal) and without liability for any act or omission of any such individual for any act
or omission made in reliance on the advice of such individual provide such person or
organization was retained with reasonable care and prudence.
O. To (i) divide any trust in this Declaration into finro or more
separate trusts by allocating to each such trust a proportionate share of each and every
substantial interest or right that had previously been held by the trust from which those
trusts were derived; and (ii) administer any addition to any such trust as a separate trust
on identical terms.
SEVENTH: Administrative Previsions.
A. Situs. The situs of this Trust is Pennsylvania and all
questions pertaining to the validity, construction, interpretation and administration of this
Trust shall be determined in accordance with the laws of Pennsylvania and the
applicable laws of the United States.
B. Jurisdiction. This Trust shall be subject to the continuing
jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania,
Orphans' Court Division.
C. Additional Propertv. The trustee is expressly authorized to
receive additional property from Claire or any other person and to administer and
distribute it as part of this Trust, provided that no additions may be made after Claire
attains age sixty-five.
D. Irrevocabilitv. Except as provided in Paragraphs E and F
below, this Trust shall be irrevocable. Nofinrithstanding any common law or statutory
provision to the contrary, neither Claire nor any legal representative acting for Claire
shall have the right to alter, amend or revoke any provision of this Trust (except as
provided below), or to withdraw any funds from this Trust.
E. Amendment. Trustee may amend this trust, without the
approval of said Orphans' Court Division, as needed so that it conforms with 42 U.S.C.
§1396p(d)(4)(A), Supplemental Security Income statutes and regulations, and any other
similar or related statutes or regulations including state statutes and regulations
governing public assistance eligibility, consistent with a primary goal of this Trust, which
is to preserve Claire's eligibility for public assistance benefits, wherever her domicile
may be located. Trustee may amend or revoke this Agreement for any other purpose
with approval of said Orphans' Court Division.
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F. Modification or Termination. In addition, anything
hereinbefore to the contrary notwithstanding, the said Orphans' Court Division shall
have the discretion to modify or terminate this Trust at any time for cause shown if it
determines that the continuance of the Trust is impractical, uneconomical or for other
reasons unwise or not it Claire's best interests. Upon any such early termination, the
trustee shall first make any distribution to the state required under Item FIRST: C. above
and any remaining principal and income shall be distributed to or for Claire's benefit in
accordance with a Decree of the said Orphans' Court Division.
G. Accrued Income. All income derived from assets received
as principal of this Trust during Claire's lifetime which has accrued when such assets
become subject to this Trust but which is received by the trustee thereafter, whether the
same is legally principal or income, shall be applied in accordance with the provisions
herein set forth for the distribution of income.
EIGHTH: Fiduciary Provisions.
A. The then acting Guardian of Claire's estate, with the
approval of the Orphans' Court Division, may at any time remove the Trustee. There
shall always be a trustee serving hereunder.
B. The trustee shall have the right to resign as trustee, provided
that the Orphans' Court Division approves the resignation and the appointment of an
appropriate successor trustee.
C. The trustee shall receive compensation for its service as
trustee hereunder and may charge the expense thereof to principal without further
approval of the Orphans' Court Division.
D. No trustee shall be required to enter bond or other security in
any jurisdiction.
E. In the event that Geoffrey B. Crego for any reason shall fail
or cease to act as Trustee, the Grantor hereby appoints Meghan Crego as successor
Trustee. In the event that Meghan Crego for any reason shall fail or cease to act as
Trustee, the Grantor hereby appoints Adam Crego as successor Trustee.
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IN WITNESS WHEREOF, the trustee, by its proper officer, and the Court by its
Order approving this Trust, a copy of which is attached, have caused this Declaration of
Trust to be executed as of , the date of the aforementioned
Order.
WITNESS: TRUSTEE:
Geoffrey B. Crego
F:�scw\5054-Crego,Geoffl13327-Incompetency Petition of Claire Wong Crego\Documents\Special Needs Trust.docx 4/22/14
1:39 PM
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EXHIBIT B
CONSENT TO APPOINTMENT AS TRUSTEE
I, Geoffrey B. Crego, hereby consent to serve as Trustee of the Claire Wong Crego
Special Needs Trust under 42 U.S.C. § 1396p(d)(4)(a). I am an adult individual who
resides at 30 North 36th Street, Camp Hill, PA 17011.
Date: o�-�,5-�-�y o
Geoffr .