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HomeMy WebLinkAbout89-0865 �J� RICHARD P. MISLITSKY, ESQUIRE Identification No. 28123 One West High Street—Suite 208 � � PO Box 1290 -� ° � =� �' Carlisle, PA 17013 � � � �:� � _;:, �4 � -.c .�a .Q 717.241.6363 � ;� � {`� �~� � F...� Y� ,�� c.:� ;_� �,;, ,.`:� � COUNSEL FOR PETITIONER `.� �� �, � � rl �, ;-�.� �.� ,-,. —r ..,,_ -r-r _.,.. `� '--1 CJ �;� C� �• r--- !�7 G"7 � � In re: Estate of Mary Aleene Burns (Deceased) : IN THE COURT OF COMMON PLEA� `'�' : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION Mary Ann Burns Taylor, : NO. ��' �q� O [�'J Petitioner/Executrix of the Estate : PETITION FOR RULE TO SHOW CAUSE PURSUANT TO C.C.R.0 206.4 (c) AND 3.2-1 AND NOW comes the Executrix of the above-captioned Estate and respectfully requests this Honorable Court to exercise its discretion and issue a Rule to Show Cause and in support thereof avers as follows: 1. Accompanying this Petition is the PETITION OF THE EXECUTRIX TO APPOINT A TRUSTEE TO MANAGE ESTATE SUB-SURFACE MINERAL RENTS AND ROYALTIES,hereinafter"Petition". 2. Petitioner is a single woman born on November 8, 1932 who resides at 111 Front Street, Boiling Springs, Cumberland County, Pennsylvania. 3. Petitioner, Mary Ann Burns Taylor, is the daughter and named Executrix in the Will of Mary Aleene Burns ("Decedent"). (Exhibit 1 of the Petition). 4. Petitioner was granted Letters Testamentary("Letters")without objection on December 1, 1989 by the Register of Wills, Cumberland County. This Honorable Court has jurisdiction not only based on domicile at the time of death,but pursuant to the Grant of Letters to the Petitioner. (Exhibit 2 of the Petition). 5. Petitioner believes and therefore avers that a Rule to Show Cause is the only practical and efficient method to bring the underlying Petition to Appoint to a conclusion in that: 1�' a) There are thirteen(13)parties with an interest in the Petition(see paragraphs 26-44 of Petition). b) Proceeding in the form of a Rule to Show Cause is the most expeditious method to determine whether there are objections to the Petition. c) To require all interested parties to file an Answer to the Petition pursuant to C.C.R.P. 3.2-1 - even if there is no objection - is believed to be unnecessary for several obvious reasons. d) Given the purpose for and relief sought by the Petition and the number of interested parties, it is respectfully submitted that following the procedure authorized by Pa R.C.P. 206.5 as adopted in C.C.R.P. 206.4 (c) is the most practical, efficient, and expeditious manner to inform all interested parties and resolve underlying issues. 6. The proposed Order granting the Rule to Show Cause places the responsibility of serving the thirteen (13) interested parties by Certified Mail on the Petitioner herein. The Rule to Show Cause, the underlying Petition, and any Order of this Honorable Court will be sent via Certified Mail/Return Receipt. As such,the burden is placed solely on the Petitioner. Wherefore, Petitioner, the Executrix of the Estate of Mary Aleene Burns, respectfully requests this Honorable Court to exercise its discretion in favor of issuing a Rule to Show Cause. Date: J � Respectfully submitted, , Ric ard P. Mislitsky, sq. - ID #2812 One West High Street—Suite 208 PO Box 1290 Carlisle, PA 17013 Counsel for Petitioner 2 � RICHARD P. MISLITSKY, ESQUIRE Identification No. 28123 One West High Street- Suite 208 PO Box 1290 �-�, Carlisle, PA 17013 c s � � 717.241.6363 � � � ,; � � -v � .�_ c� ..�7 �:t� C� "C �+] :,t:7 COUNSEL FOR PETITIONER __ ��; rT.� N ,:��d t�'a =��. -- ..,.. f-.. .:,� �, �. �:,r> .- . „.� . , . �,�, -.;., -�, ``' r.,' °:,r � ._ -�-r � � _ .: :U � � � In re: Estate of Mary Aleene Burns (Deceased) : IN THE COURT OF COMMO�P�EAS �'- : CUMBERLAND COUNTY, PENNSYLV�IA� -� : ORPHANS COU T DIVISION Mary Ann Burns Taylor, : NO. /V� � � �4 �� Petitioner/Executrix of the Estate : PETITION OF THE EXECUTRIX TO APPOINT A TRUSTEE TO MANAGE ESTATE SUB-SURFACE MINERAL RENTS AND ROYALTIES AND NOW, comes the Petitioner, Mary Ann Burns Taylor, the named Executrix in the Last Will and Testament (hereafter"Will") of Mary Aleene Burns (deceased) and prays this Honorable Court to grant the Petition allowing the Executrix to place estate assets into a Trust and appoint a Trustee hereinafter set forth that will, in the future,manage the estate assets, and in support as follows: I. EXECUTRIX 1. Petitioner is a single woman born on November 8, 1932 who resides at 111 Front Street, Boiling Springs, Cumberland County, Pennsylvania. 2. Petitioner, Mary Ann Burns Taylor, is the daughter and named Executrix in the Will of Mary Aleene Burns ("DecedenY'). A copy of the Will is attached hereto and identified as Exhibit 1. 3. Petitioner was granted Letters Testamentary ("Letters") without objection on December 1, 1989 by the Register of Wills, Cumberland County. A copy of the Letters is attached hereto and identified as Exhibit 2. This Honorable Court has jurisdiction not only based on domicile at the time of death,but pursuant to the Grant of Letters to the Petitioner. � � II. BACKGROUND 4. Petitioner incorporates by reference the averments contained in the preceding paragraphs 1-3, as though same were fully set forth herein at length. 5. For the Court's convenience, and pertinent to this Petition, the assets herein at issue are provided for in Item 3 of Decedent's Will,previously identified as Exhibit 1. 6. The Assets herein at issue are sub-surface mineral rights as follows: a) A 107.04 acre farm situate in Butler County, Pennsylvania. Said 107.04 acres consists of a parcel of 25.68 acres (260-1F53-20A-000) and an 81.36 acre parcel (260-1F53-20-000). A copy of both tax bills are attached hereto and identified as Exhibit 3. The Estate maintains all surface rights to the Farm as well as sub-surface rights for coal and gas. Sub-surface oil rights are subject to a long-standing lease presently held by Rothman Gas and Oil. Rothman extracts oil and deposits the extracted oil into a pipeline owned by Ergon Oil Purchasing, Inc. The beneficiaries of the Estate receive royalty checks from Ergon. A copy of the 1099-MISC is attached hereto and identified as Exhibit 4; and b) Four sub-surface mineral leases corresponding to lands located in Cambria County and Indiana County, Pennsylvania. The beneficiaries of the Estate receive royalty checks from three of the four corporate lessees —XTO Energy Inc., Resource Energy, LLC, and Victory Energy Corporation. Evidence of payments from the three (3) corporate lessees, is attached hereto and collectively identified as Exhibit 5. The fourth corporate lessee, Chevron USA, Inc., is not so deposited for the reason set forth in paragraph 10 hereof. 7. Executrix has managed these assets from the time of Decedent's death to the present. 8. Item 3 of Decedent's Will named four "original beneficiaries", the natural-born children of the Decedent, Mary Aleene Burns, and her husband, Arthur Roscoe Burns, (father of the Petitioner, who predeceased Mary Aleene Burns.) The "original beneficiaries" are identified in paragraphs 26, 27, 28, and 36 hereof. 9. Two of the original beneficiaries, Thomas Clark Burns ("Thomas") and Walter Arthur Burns, ("Walter") are deceased. Petitioner has been advised that both Thomas and Walter died intestate. Petitioner has been further advised that the Estate of Thomas passed to his heirs pursuant to the laws of Florida; Petitioner has also been advised that the Estate of Walter passed to his heirs pursuant to the laws of New Mexico. Petitioner demands proof of the intestacy of both Thomas and Walter and further demands proof of the intestacy heirs. 10. The Petitioner has maintained an Estate Account into which she deposits all rents and royalties received by the Estate from the three corporate lessees named in paragraph 6 b) above. As directed, she makes distributions from the account to the surviving spouses of Thomas and Walter and their presumptive heirs, with the exception of Chevron USA, Inc. Without the consent or approval of the Executrix, the fourth corporate lessee Chevron USA, Inc. began distributing rents and royalties directly to the spouses and children of Thomas and Walter. 2 III. PURPOSE AND AUTHORITY FOR PETITION 11. Petitioner incorporates by reference the averments contained in the preceding paragraphs 1-10, as though same were fully set forth herein at length. 12. Among other provisions of the Pennsylvania Estate and Fiduciary Code (PEF Code or "Code") and pursuant to provisions of the Fiduciaries Act of 1947 (20 P.S. § 320 et seq.), § 3321 (c) of the Code specifically permits a personal representative to employ a manager to act as attorney- in-fact. Also, as a matter of law, the Executrix and anyone charged with the fiduciary obligation of administering an Estate, have broad, discretionary powers to administer the estate as they see fit. 13. The purpose of this Petition is to secure judicial approval, allowing the Petitioner to appoint a Trustee, and to place Estate assets into the Trust to be administered for the financial advantage of present and future beneficiaries. 14. Since receiving Letters (Exhibit 2), the Petitioner has been performing her duties as Executrix, which include but are not limited to: a) Collecting rents and royalties from those holding sub-surface mineral rights; b) Distributing the rent and royalties to the beneficiaries as she was directed to do by the spouses of the deceased beneficiaries, therefore, payments due to Walter's estate were being made to Walter's surviving spouse, Ann Louise Burns, and payments to the estate of Thomas were being made to the surviving spouse, Mary Lee Burns. c) Receiving offers for sub-surface coal and gas rights from competitors of the present corporate lessees; d) Receiving offers for sub-surface oil rights on those assets which only pertain to shale gas; e) Maintaining records for the preparation and filing of tax returns for the Estate and annually filing all necessary federal and state taxes; fl Receiving requests to renegotiate rights to the sub-surface mineral rights, or to terminate existing leases and enter into agreements with competing corporations for said rights; g) Resolving disputes between the adjacent property owners and the corporate lessees, and; h) All other necessary functions arising from her duties as Executrix of the Estate. 15. Petitioner believes and therefore avers that any attempt by her to exercise her authority as Executrix to appoint a Trustee will meet with objections from at least one of the presumptive heirs of the two deceased original beneficiaries, as well as at least one corporate lessee of the sub-surface mineral rights, Chevron. (See paragraph 10 hereo�. Petitioner again affirmatively 3 avers that those corporate lessees holding rights to extract sub-surface minerals ARE NOT interested parties and have no standing. 16. Petitioner believes and therefore avers that one of the presumptive heirs of the deceased original beneficiaries has initiated communication with various corporate lessees, including Chevron, and without the consent from and without the authority of the Executrix and based on such communications, has requested that rent and royalty payments be made directly to the presumptive heirs of the two deceased original beneficiaries and not to the Executrix of the Estate, as required by law. 17. As previously averred herein, Chevron USA, Inc., a corporate lessee, has been making payments directly to the presumptive heirs of the deceased original beneficiaries over the objections of the Executrix; without legal authority to do so, and without a legal determination establishing entitlement to such payments. 18. In addition, the Petitioner has recently received forms from the corporate lessee, XTO Energy, Inc. requesting information which would allow rent and royalty checks to be paid directly to the same individuals as referred to in paragraph 17. The Executrix did not request said forms, or initiate any discussions with XTO Energy. Petitioner objects to any distributions of rents and royalties other than to the Estate. 19. Petitioner affirmatively avers that she made no such inquiry to XTO Energy, and did not extend that authority to Chevron. 20. Petitioner does not have in her possession all the lease agreements which transfer the sub-surface mineral rights to the corporate lessees. The proposed Trustee (see paragraph 53) shall, among other functions, obtain all current leases and review same for potential benefits to all beneficiaries. Petitioner affirmatively avers that the Estate is entitled to received rents and royalties from the following companies: • XTO Energy, Inc. 810 Houston Street Fort Worth, TX 76102-6298 • Chevron USA, Inc. PO Box 9035, SEC-862 Concord, CA 94524-1935 • Resource Energy, LLC 3500 Massilon Road, Suite 100 Uniontown, OH 44685 • Ergon Oil PO Box 356 Newell,WV 26050-0356 4 • VECandS &D 220 Airport Road Indiana,PA 15701 IV. INTERESTED PARTIES 21. Petitioner incorporates by reference the averments contained in the preceding paragraphs 1-20, as though same were fully set forth herein at length. 22. Petitioner believes and therefore avers that the previously named corporate lessees lack standing and have no right in law or fact to contest this Petition, and as such, they should are not be considered as Interested Parties herein. 23. At all times material hereto, the Will provision relevant to this Petition, Item 3 of Decedent's Will names her four (4) natural-born children as beneficiaries of the rents and royalties arising from the mineral rights owned by the Estate. (See Exhibit l, Item 3) 24. Although not relevant to this Petition, Counsel believes it necessary to point out that Item 5 of Decedent's Will names two (2) additional beneficiaries Susan Jane Bradshaw and David Stewart Burns. 25. It is affirmatively averred that the remainder of the Estate has been distributed as set forth in Item 5. The beneficiaries named in the preceding paragraph have both received the benefits provided for in the Will. Accordingly, Petitioner therefore avers that only Item 3 of the Will is relevant to this Petition. 26. Of the four (4) original beneficiaries of the Will, in addition to the Petitioner, only Joseph Whitfield Burns survives. 27. Joseph Whitfield Burns is a single man, born on August 1, 1940 who maintains his residence at 113 Front Street, Boiling Springs, Cumberland County, Pennsylvania, with a mailing address of PO Box 326, Boiling Springs, Pennsylvania 17007. Joseph Whitfield Burns joins with Petitioner in support of this Petition. 28. Thomas Clark Burns, previously identified as an "original beneficiary" and thereafter referred to as "Thomas", died on November 26, 2005. At the time of death, Thomas lived and resided at 7150 Estero Boulevard, Unit 903, Fort Myers, Florida. 29. Petitioner has no independent knowledge, but has been advised, that Thomas died intestate and that his assets, if any, were distributed without probate. Petitioner believes that verification of the above is required, and demands strict proof. 30. Petitioner, without independent knowledge, has been advised that Thomas died, leaving a surviving spouse, Mary Lee Burns, and four(4) children: 5 Thomas Clark Burns Timothy Martin Burns Martin Arthur Burns Lee Ann Burns DeSaia 31. Mary Lee Burns, the surviving spouse of Thomas, resides at 7150 Estero Boulevard, Unit 903, Fort Myers, Florida 33931. 32. Thomas Clark Burns, son of Thomas,resides at 928 Bay Sky Way, Sea Brook, TX 77586. 33. Timothy Martin Burns, son of Thomas, resides at 2130 Smokey View Boulevard, Powell, OH 43065. � 34. Martin Arthur Burns, son of Thomas,resides at 368 Brown Road, Wyalusing, PA 18853. 35. Lee Ann Burns DeSaia, daughter of Thomas, resides at 80 Woodland Drive, Powell OH 43065. 36. The original beneficiary, Walter Arthur Burns ("Walter") son of Decedent, an original beneficiary in Item 3 of the aforesaid Will, died on March 27, 1996. At the time of death, Walter resided at 507 G Avenue, Carrizozo,New Mexico 88301. 37. By letter dated August 18, 2013, James H. Owen, Esq., informed the undersigned that Ann Burns, surviving spouse of Walter, through counsel, opened the Estate of Walter A. Burns in Butler County, Pennsylvania, despite the domicile at time of death. Petitioner has been advised that Ann Burns has been appointed as Administrator of the Estate. A copy of the Short Certificate and the correspondence from Attorney Owen are attached hereto and collectively identified as Exhibit 6. 38. As counsel for the Estate of Walter A. Burns, James H. Owen, Esq. maintains an office at, and conducts business from The Old Library, 200 North Jefferson Street, Kittanning, Pennsylvania 16201. 39. Petitioner believes and therefore avers that as counsel for the Estate, Attorney Owen, is in the best position to address this Petition on behalf of the beneficiaries of the original beneficiary, Walter A. Burns. In addition, as counsel of record, Petitioner believes that all notices including notice of petition and the Rule to Show Cause should be served on Attorney Owen as well as the presumptive heirs of Walter as hereinafter set forth. For purposes of this Petition and for the convenience of this Court, the children of Walter and Ann Burns are: James Scott Burns Robin Elizabeth Burns DuBois Heather Jean Burns Alberth Rachel Aleene Burns Crowley 40. Ann Louise Schlatter Burns, wife of Walter, resides at 516 Locust Street, Kittanning, PA 16201. 6 41. James Scott Burns, son of Walter, resides at 808 Centerwood Court, Brandon, FL 33511. 42. Robin Elizabeth Burns DuBois, daughter of Walter, resides at 453 Surrena Road, Harrisville, PA 16038. 43. Heather Jean Burns Alberth, daughter of Walter, resides at 9 Bairdford Park Road, Gibsonia, PA 15044; 44. Rachel Aleene Burns Crowley, daughter of Walter, resides at 202 Georgetown Lane, Export, PA 15632. 45. As stated in paragraph 39, Petitioner herein intends to not only serve Attorney Owen, but also Ann Burns and each child pursuant to PEF Code § 768. V. INTENTION OF THE EXECUTRIX 46. Petitioner incorporates by reference the averments contained in the preceding paragraphs 1-45, as though same were fully set forth herein at length. 47. Petitioner's increasing age; the growing responsibilities of administering the Estate assets; and the increasing complexity of managing the Estate assets - especially the sub-surface shale gas rights - have collectively forced Petitioner to the conclusion that in order to effectuate the intent of her mother, the Decedent Mary Aleene Burns, (as well as her deceased father) it is necessary to appoint an Institutional Asset Manager as Trustee of the Estate, and the assets to be placed in Trust. It is believed that such would not only further the intent of the Decedent,but also is in the best interest of the existing and future heirs of the Decedent. 48. Petitioner affirmatively avers that the intent of the Decedent, following the directive of Decedent's husband (Arthur Roscoe Burns, father of Petitioner and the original beneficiaries) was to preserve the assets herein at issue far the economic benefit and security of future generations. It should be noted that decedent's husband, Arthur Roscoe Burns, was an astute petroleum engineer who began to accumulate sub-surface mineral rights as early as 1930 for the specific purpose of providing revenue to future generations, and directed decedent and his children, the original beneficiaries, to maintain ownership of the sub-surface mineral rights as such will increase in value in the future. 49. The Petitioner affirmatively avers that in order to effectuate the intent of the Decedent, the Estate assets must be preserved with all rents and royalties flowing to the legal beneficiaries as well as future descendants of the Decedent. 50. After due diligence and investigation, Petitioner has selected an institutional Trustee to manage said assets, as described in paragraphs 52-56 hereof. 51. Petitioner believes and therefore avers that appointment of a Trustee best serves the interests of the present beneficiaries and future descendants of decedent and her husband. In support thereof offers the following for consideration: 7 a) The assets at issue are situate in three western Pennsylvanian counties— Cambria, Butler, and Indiana. The locations of the "assets" are far-removed from all but two (2) of the current beneficiaries, neither of whom has expressed the desire to manage the Estate assets; b) Due to the location of the assets, it is best that the Trustee should be in a location, or have an office, in close proximity to said assets; c) Due to the complexity of managing sub-surface mineral rights, and the rents and royalties flowing therefrom, which have steadily increased with exploration and production of shale gas, Petitioner believes that the best interests of all those currently entitled to share in Estate revenues as well as those in the future, is best served by having a Trustee with experience in managing such assets. Petitioner believes and therefore avers that the difficulties and complexities will continue to increase as a result of the increased demand and competition for shale gas production, and the pipelines necessary to efficiently transport the gas; d) The presence of shale gas, and the increased income arising therefrom, strongly suggests that the value of the Estate assets will certainly increase in the future, all to the financial benefit of current and future beneficiaries. It is for this reason that the Petitioner believes that the Estate assets should be maintained and not liquidated; e) Item 3 of Decedent's Will, passes to the beneficiaries therein per stirpes. As a result, since time of Decedent's death, there are more beneficiaries than the four (4) original beneficiaries. Despite the increased number of beneficiaries, it is believed and therefore averred that the increasing value of shale gas production will continue to be to the financial benefit of all those entitled to share in the rents and royalties now and in the future. � In addition, if the intent of the Decedent (and her husband, Arthur Roscoe Burns) is to be effectuated, the Estate assets and the rents and royalties payable to the Estate MUST be preserved into the future. Petitioner believes and therefore avers that as the number of descendants increases, the complexity and importance of properly managing Estate assets will increase in the future. g) Petitioner respectfully submits to this Honorable Court that there must be an experienced manager appointed. Shale gas leases are technical and confusing. It is imperative that an experienced entity be appointed to both enforce the technical provisions of the leases, and as illustrated in h)below, to guarantee proper accounting of rents and royalty payments. h) As described in paragraphs 6 (b) and 10 hereof, without the consent or note to the Executrix, Chevron USA began sending individual lease payments to each beneficiary. As the number of beneficiaries increases, it will be impossible for anyone but an asset manager with significant experience in administering sub-surface mineral leases, particularly shale gas leases, to monitor rent/royalty payments and to accurately distribute payrnents to the beneficiaries. 8 52. Your Petitioner has searched for an appropriate institution to serve as Trustee and has personally interviewed recommended individuals and institutions. 53. Petitioner believes and therefore avers that S & T Bank, 800 Philadelphia Street, PO Box 220, Indiana, Pennsylvania 15701 is best suited to act as Trustee to manage the Estate assets. 54. Petitioner and counsel have, on several occasions, spoken to and met with the Vice President, Director of Mineral Management, C. Wesley Turiano, who represents S & T Bank in matters involving sub-surface minerals. 55. Attached hereto and collectively marked Exhibit 7 is information provided by Mr. Turiano which includes: • A proposed Oil and Gas Management Agency Agreement • Fee schedule • Brochure setting forth the services provided by S &T • Mr. Turiano's resume 56. For the reasons set forth herein, Petitioner submits that a Trustee is necessary to manage the Estate assets in the future, and further submits that, after due diligence, S & T Mineral Management is best suited to serve in this matter. VI. OTHER CONSIDERATIONS FOR THE COURT 57. Petitioner incorporates by reference the averments contained in the preceding paragraphs, as though same were fully set forth herein at length. 58. Petitioner has discussed the reasons prompting this Petition, as set forth herein, with the current beneficiaries. Petitioner believes and therefore avers that at least one of those who are presumably entitled to share in the Estate of the deceased original beneficiaries, Thomas and Walter, are unwilling to allow Petitioner/Executrix to transfer her responsibilities to a Trustee. Petitioner believes that action by this Honorable Court is therefore required. 59. Both of the original surviving beneficiaries in decedent's Will (Petitioner and Joseph W. Burns) agree that to effectuate the intent of the decedent, the Estate assets must not be liquidated, but to the contrary, must be maintained as Estate assets for the continuing benefit of future descendants of the decedent and her husband. It is further averred that Joseph W. Burns joins in the relief sought by Petitioner. 60. Petitioner welcomes any opportunity to resolve the issues herein presented by mutual agreement. She is also very willing to discuss the terms of any agreement involving an Institutional Asset Manager/Trustee and/or to have this Honorable Court act pursuant to § 3323 of the PEF Code. 9 Wherefore, Petitioner requests this Honorable Court for the following relief l. To issue upon the heirs of the deceased a Rule to Show Cause, which is being filed contemporaneously with this Petition, why Petitioner should not be allowed to appoint, with judicial approval, S & T Bank as Trustee of the Estate assets. For purposes of service process, a list of heirs is attached hereto and identified as Exhibit 8. 2. In the event of opposition to this Petition, Petitioner asks the Court to schedule an Evidentiary Hearing to determine the merits of any opposition. 3. Issue a Decree creating a Trust and placing the Estate assets set forth herein into the Trust. 4. Issue a Decree appointing S & T Bank as Trustee to manage the Estate assets held in Trust. 5. Exercise its power pursuant to § 3323 of the PEF Code. If this Honorable Court, in its sound discretion, believes that continued oversight of the Estate is necessary, Petitioner agrees to submit to the Court for approval, the Trust document to be agreed upon by the Petitioner and the Trustee named herein. 6. Issue an Order compelling Chevron USA, Inc. to cease making distributions to the individuals named herein and from the date of the Decree to make payments to the Trust, and to provide the Trustee with an accounting of gas extracted and payments made for five (5) years prior to 2014. 7. Such other relief that the Court may deem equitable and proper. Date: � ( � I Respectfully submitted, , �� . ��, ichard P. Mislitsky, sq. - ID #28123 One West High Street— Suite 208 PO Box 1290 Carlisle, PA 17013 Counsel for Petitioner 10 VERIFICATION I,Mary Ann Burns Taylor, Petitioner in this matter, acknowledge that I have read the foregoing PETITION OF THE EXECUTRIX TO APPOINT A TRUSTEE TO MANAGE ESTATE SUB- SURFACE MINERAL RENTS AND ROYALTIES. I verify that my avennents in this Petition are true, correct and based upon my personal knowledge (or are true and correct to the best of my knowledge, information and belie�. By signing this Verification I acknowledge that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Date: � � � M Ann Burns Taylor �� EXHIBIT 1 ,'�;,_, , , ._..----�. ,�.."'� LAST WILL AND TESTAMENT OF MARY ALEENE BURNS I , MARY ALEENE BURNS a resident of Main Street , Wyalusing, Bradford County, Pennsylvania being of sound mind, memory and understanding, do hereby make, publish and declare this to be my Last Will and Testament, hereby revoking all Wills and Codicils heretofore made by me. ITEM 1 : I direct that all my just debts , the expenses of my last illness and funeral expenses be paid as soon after my decease as the same can conveniently be done. ITEM 2: I direct that there shall be paid out of my residuary estate all estate, inheritance and iike taxes zogether with any interest or penalty thereon imposed by the government of the United States, or any state or territory thereof� or by any foreign government or political subdivision thereof, in respect to all property required to be included in my gross estate for estate, inheritance or like tax purposes by any of such govern- ments , whether the property passes under this Will or otherwise, excluding, however , any property over which I have a taxable power of appointment, provided, however, that no residuary beneficiary shall by reason of this provision be denied the benefit of any deduction, credit , favorable rate of tax or other benefit which by law enures to such beneficiary. � ,., � ����%l ��.��GP Cl/ /�����'� � M V f1� C` �tr. nrt.�wt'+ ° r.� ,.�...�.� �.� -�.�..�.�..� .� e. _ . � .� � � - . W _ —— LAST WILL AND TESTAMENT OF MARY ALEENE BURNS ITEM 3: I give , devise and bequeath , in equal shares, unto MARY ANN TAYLOR, THOMAS C. BURNS, WALTER A. BURNS and JOSEPH W. .... BURNS, the following property: � A. The interest owned by me in the Campbell Farm ; situated in Parker Township, Butler County; , ; B. All mineral rights owned by me at the time of my � i � death in any real estate; and C. All stocks owned by me at the time of my death. ITEM 4: If and in the event that one of my natural children I set forth above under Item 3 does not survive me and is not living � sixty (60) days af ter the date of my death, then and in such event , I give , devise and bequeath the interest in the property identified in Item 3 above which such deceased natural child would have received, if living, to the issue of said deceased natural child, per stirpes. � ITEM 5: I give , devise and bequeath all of the rest, residue � and remainder of my estate, and wheresoever situate at the time of my death, in equal shares, unto MARY ANN TAYLOR, THOMAS C. BURNS , WALTER A. BURNS , JOSEPH W. BURNS , SUSAN J . GORDY, and DAVID S . BURNS provided , however , that they survive me and are living sixty (60) days after the date of my death. ��A '. �, [.� � �,� 2� , � �—.----— - LAST WILL AND TESTAMENT OF MARY ALEENE� BURNS ITEM 6: If and in the event any one of my children listed above under Item 5 does not survive me and is not living sixty (60) days after the date of my death, then and in such event, I t give, devise and bequeath the interest in my estate set forth above in Item 5 which such deceased child would have received, if l living, to the issue of said deceased child, per stirpes. � ; ITEM 7: I hereby nominate , constitute and appoint my daughter, MARY ANN TAYLOR, Executrix, of this my Last Will and � I iTestament, with full power to do any and all things necessary for the comp�ete adn�inistration of rny estate , arid direct that no bond Ior other surety is required of her in this or any other jurisdiction for her performance of this office. If and in the event that my said daughter, MARY ANN TAYLOR, does not survive me and is not living sixty (60) days after the date of my death, or does not complete her duties as Exec�trix, � then and in such event, I hereby nominate , constitute and appoint t ` my son, THOMAS C. BURNS , Executor, of this my Last Will and � Testament � with full power to do any and all things necessary for jthe complete administration of my estate , and direct that no bond or other surety is required of him in this or �any other � jurisdiction for his performance of this office. , i , � ,. �, ,, MA AL NE BURNS . �„�m ��� ...�,. . . _ �� �•; ; � , � � �-- - -- _ LAST WILL AND TESTAMENT OF ' MARY ALEENE BURNS I ! � ITEM 8: If any provision of this Will or of any Codicil � 1 i hereto is held to be inoperative� invalid or illegal � it is my ; intention that all the remaining provisions thereof shall continue to be fully operative and effective, so far as is possible and reasonable. IN WITNESS WHEREOF, I , MARY ALEENE BURNS , the Testatrix, have ito this my Last Will and Testamen t, typewritten on four (4) i i consecutivel numbered y pages, subscribed my name and affixed my I seal this f�� day of`� � ggs, (SEAL) Signed, sealed, published and declared by the above named MARy � ALEENE BURNS , as and for her Last Will and Testament� in the presence of us, who have hereunto subscribed our names at her request, ,as wii;nesses hereto, in the presence of the said Testatrix, and eac other. - � ' � siding at , c _ � residing at ' -4- EXHIBIT 2 . . .• . �.--_1� ' " • ^��. �ry g Certificate of Grant of Letters A No. 21 - 89 - 865 ESTATE OF �RY ALEENE BURNS \ �. ,.. , Social Security No. 16 7 - 3 6 _ 2 9 9 9 WHEREAS, on the 1 ST day of DEC, g g ------_, 19 instrument(s) dated=_______ PJOVEMBER 11 1985 was (were) admitted to probate as the last will of �$Y AT FFNF RiTR t� Iate of_ SOTimH MIDDLETON TWP , who died on the 23RD day of NOVEMBER � 19 $2_, and WHEREAS, a true copy of the wi11 as probated is annexed hereto. THEREFORE, 1, MARY C. LEWIS , Register of Wills in and for the County of Curnberiand,in the Commonwealth of Pennsylvania,hereby certify that I have this day granted Letters TESTAMENTARY to MARY ANN TAYLOR who ha S duly qualified as EXECUTRIX � and h�_agreed to administer the estate according to law,all of which fuliy appears of record in my Office at CARLISLE , Pennsylvania. 1N TESTIMONY WHEREOF,I have hereunto set my hand and affixed the seal of my Of'6ce the 1ST day of DECEMBER , 158 9 - _ . _ _ _ _ _ w ' �n H Ol �D x o0 00 a � � � � � �� �C o • rn �.a c°> L o � u) HH � ao � N � � � p O � v � �3= � �n N � W � �C q c�v (�O p ' c � m� a H WW � m �►- � �a � ° aw � zaw ° 2 �wo d � N a w � o �+ cn A w �� ¢ E � w H xw cn � w H W � � w cEna � oaww v`�i c�'n U � a w � � cnuaA H . w • ,;�, �u,,, � �, , • . , � . , ,� .� ;: . ,.:. � � �_. .� � _. ' � . ::. 1 : �:��;' _ _ EXHIBIT 3 ��r� � a000 d' � � N O O tn N � 00 O O (`1 � � �t1 O O O t[1 � • • • • • 0 E- c-1 � � N � F M � � p� � tf1 . 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Q m o irn r.,� � ,_Wj o Q �� � � �a-1 � W 'F.. ri t-1 lo o F-1 r-1 � !d O H rl W tY N � m w �w N � � iU • V] �C � � m i c� • cn FC � w �W _ a E-+ a+ m o .. �� � aHa m � � ;a `-' w � x ° � Q o '-� � � a � W > o ;:. a w a , 9 Q o ,= �+ H � „ c IJ�- y�7., H�y [�[i��jj]] > � �„ , a a4 m m a � � . 1 F� C p � . . • . _ �.m � C b � � � N � -O pN � 'T Q . � � N LL a` Q C O Q j � c� W a` Q G O � i _ _ _ EXHIBIT 4 ----- � Q� N 'C � M W C.� � a+ x w o o m� ��mcAr cv � � . m i+ � ` � � m m = ��..��o `o � K m I �¢ , � � C vvc�_c� o_ipo� g . � �O. . � 3 y O �7„ � I � � � �+ m ��coo�'-ooarEa���a I •C--± � 0 � m O.C � � n � � O Q' t�l�=°o�°.«•—°-°oEc�rsmoa ton !� C U � .� � � c 9 � = V m E€?�°P�°�°n°°�°°� � p�' Eci�m�t'iaY �L m ( � oo_p m�� oo p I o .. � . ' - � 3 � L Q ��$��0 7 a�� �� t � . I •' � LL F-' Y N � $ O G 4 � � N I � �� ' !� _ lL' i'n 7 o :n : � E o I F- ( � T. . � Cl 1 � � � ~ � �f.. 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YOUR TOTALS 3670.49 .00 .00 3670.49 F-FUEL C-CON�ENSkTF 1�lRY AI.EENE BQRNS EST OWNER NUMBER CHECK DATE G-Gns �-Cr�eoH�oxit� 1+�iRY AHId TAYIAR E�CUTRI% H-HEL.ItA�A L-NATURAL GAS llQUIDS PROOUCr o-a� A N-NETPROFFTS Po BOx 337 0332440 6(25i13 � ,N R-�siot� P-�nrtT�aoucr SOILZNG SPRINGS, PA 17007 S-SULFUR Q-MINIMUM ROYALTY T-�NTEREST OWNER TYPE:W-WORKING R-ROYAITY O-OVERRIDE CHECK NO. 6167�77 E-EXCESS ROYALTY P-PRODUCTION PAYMENT pyyNER NAME XTO ENERGY INC. .TON ST.-FORT WOR7H,TEXAS 76102-6298 DETACH AND RE7AIN THIS STATEMENT FOR TAX PURPOSES,DUPLICATES CANNOT BE FURNISHED. 866-886-2613 753385 0621 008035 016070 2/2 � - - - - _ . . _-- � z � � _ � � � a . vr � � �, Z w � � o 'usg �, ; Z Q p lp U u�i Z ' � p �[t � o � ��.{ ON � � r.,� M tt� } 3 � � 'r �� 0 � �, o � � '-� � o ° oo ° ° W °° W � ¢ W o0 0o xo3 � W . . c� � s o ° �; � � � � � � W � � a � � � w a ,� � �1t W � x 1 � � A � h 00 p p O �{` � � 4 F�a- � � 1 ('� � � � N � � t� �b � w � Q 0 � � O � �' ��� � � � � � `.� '� � N • �: � ua U�N � j � � ap ap I 00 ISl � � NO � t..� pp0 � `! 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(J� � w O . G7 � �a N � � v EXHIBIT 6 Law Offices of James H. Owen � Attorney at Law Tf�OLD LIBRATtY LEE J.CAI.AItIE JAMES H.O WEN 200 NOR�I JEF��R50N STREET of co�msel KI'ITANNING,PA 16201 TFr:RT'HONE:(T24)548-8]65 pETER CALARIE rf1�(724)548-8644 1908-2002 August 18, 2013 Richard P. Mislitsky, Esquire Attorney at Law One West High Street PO Box 1290 Car[isle,PA 17013 RE: Estate of Mary Burns Dear Mr. Mislitsky: � P[ease be advised that an behalf of Ann Burns we receritly opened an estate for Walter Arthur Burns in Butier County, Pennsylvania. You v�ri�E find enclosec! a copy of the Short Certificate issued by the Register of Witls af Butler County. . Ann Burns, as Administrafirix of the Waltei' Burns Estate, has asked #hat I corr�spond with you and ask�khat any and a11 further correspandence regarding Walter Burns' interest in the Mary Burns Estate be directed to me. We have begun to put together information necessary to file a Pennsylvania Non-Resicient tnheritance Tax Return. We are hopeful that as this process continues we \ wili be able to further address the var"bus issues raised by your correspondence. 1 laak forward to hearing from you further. ,V� truly yours, .-----�,. ��`��-'� J s H.Owen, Esquire . JHOf mo. Enc(osure c: Ann Burns � �udi�h. ..tV.�oser, M.S. . . , R,EGIST"ER OF WILLS � Butier County, Pennsylvania �+�Cl.ERK p� � � �c�`� o�Ati , O �2 . � � . � � � Short �'erii cafe � o � � - a� � * e � .o�?ZFR cnV�A �HNSYl.a1PN T, 3UDITH MOSER, M.S., Register of Wills in and far the County of Butler,Pennsylv�nia. DO HEREBY CER7'IFY that on July 29, 20�,LETTERS OF ADMIlIFISTRATION an the F�tate of WAI.TERARTHUR BLTRNS, � late of CARR7Z4Z0 LINCOLN COUN�'Y NEW MEXICO,cieceased,were granted ta , ANN L.BURNS , having first been qualified well and truly to administer the sama Arid I fiirther certify that said Letters have not been revaked. IN?�STID�ONYW.FIF�REOF,I have unto set my hand and seal of said office at BiTTLER, PENNSYI.VANIA,4n Julv 29, 2o��C. �1e No: �.a-�-o63S Date of Death: March 2fi, �996 . S.S.#: �.64-28-go66 � IUDITAM�SE$M.,� Regisier of WifFs&Cierk of Orp6ans'Coart A�y C.omwiasasi&=g�v+Piret Moa8�9.Jar�a*Y,2416. NOT VALID WI1�i0UT OFFICIAL SIGNAT[JRE AND SEAL 4F OFFICE _ _, EXHIBIT 7 5&T BANK Oi! and Gas Mana_gement Agency Agreement Pw-suaix to the cerms and condicions of this Oil and Gas Management Agency Agreement (the "Agreemer�t"), the undersigned, eicher individually ar collecuvely, as printipal ("Principal"j, hereby appoin�s S&fi Bank dlbla S&T Mineral Managemenc as agent fo�•and on behalf of Pr-incipa) ("Ageni'}, and Agenc hereby accepts Principal's appointrnent, co perform mineral managemenc functions wich respect to che oil and gas interests ("Interescs") in the proper�ies owned by Principal and rnanaged by the Agenr. her-eunder, including the following: I. Negodacion and Exec��tion of Oil and Gas Agreemencs a. Oil and Gas Leases b. Pipeline Right of Ways c. Wel) Pad Site Agreement d. Seismic Testing Agreement e. l.ease Amendmenc or Rat;fication f. OCher Surface Use Agreemencs 2. Verification and Processing of Division Orders 3. Revenue Processing,Verificacion, and Distribution 4. Payment of Ad Valorem Taxes and Other Property Taxes 5. Property Title and Deed Searches 6. Evaluating and advising on well proposals 7. Review and respond to regulatory proceedings Afl funds which are payable co Prin�ipal under any Icases and other contracts reladng co the Interests � shall be �-eceived by Agent pursuant to a dedicated lockbox facility (acated in indiana. Pennsylvania. Agent shail hold and deposit all such funds in a tustody account maincained by Agenc for tl�e b�nefit af t'rincipal, and shall separately maintain and accounc for aMl such funds, and tlie interest thereon, artribucable to rhe lnterests. Agenc may invest all such funds in Agenc's own bank deposit products, inciuding ics propriec��ry money market deposit account, at prevailing market races. Funds will be held and maincained in said custody account, pending their distribution to Principal's desired demand deposic account pursuant to this Agreement. During the t:c�nn ef this Agreemenc, Ageric shall provide ac least quarterly, wricten or electronic reports to i'rir�ci�al which decails a11 transaaions that have occurred d�ring the period. Unless Principal abjects iri wri�ing within fifteen (15) days of the date of such statement. Priricipai agrees chat the transactions set farch in such stacemenc shaU be accurace, complece and conclusive in a!I respeccs. + The compensation c�f Agent for its services shalE be paid monthly and shall be in accordance wich the attached fee schedule. Subjecc to applicable law, Agenc shall not be liable for any claims, (osses, liabilities, da�nages or expenses ("Losses") m�ide or incur-a-ed by Principa) as a resuit of d+e services provided by Agenc hereunder except such Losses which directly result from or are rela�ed to Agent s willful misconduct or gross negligence. During che term of chis Agreement, Agent shall have the authoricy an behalf af Principal co (a) lease ches Interes�s, or to re-lease any leases presently in effect upon their expiration or termination, pending fina! approvaf of a negotiated Agreement by the Principal, (b) execute all division, transfer and similar orders required by Che purchaser- of produccion pertaining or allocable to any Interesc or (c) pay any and all t�xes and charges assessed against the (nte►•ests relating to the services provided hereunder from funds held in the cuscody account. This Agreemenc percains co the fnterests specified by Principal. At tl�e written direction o(Principal, che Agcn� may provide ti�e abave specified services to any additional Interescs under and subjecc to che �erms of chi's Agreement. Either Principal or Agent n�ay terminate this Agreeinent upon at {east sixty (b�) days' prior written nocice. Upon termination, Agent shalh (a) render a final a�touncing for all lncerescs subjecc co chis Agreement, (b) cransfer and deliver to Principal or at�y other party designated by Principal, all func:s held by Agent hereunder on behalf of Principa( and (c) promptly execuce all inscruments and documents which may be reasonably necessary to fully effiect the termination of this Agreement and che transfer of funds and ocher assets to Principal or its designee. This Agreemenc shall be consu-ued and applied in accordance with che laws of zhe Commonwealth of Pennsy{vania, which law shall govern all matters in connection with this Agreement. Principal ac1<nowiedges and undersG�nds thac all actions undertaken by Agent hereunder may be delegaced to and performed by affiiiaced and unaffiliated parties locared within or oucside of the Con-�monwealch of PE:�7nsylvania. (N WITNESS WHEREOF, the parties hereto have executed this Oil and Gas Management Ag,ency Agrecme�t as ai the date set forth under Agent's s�gnature below. PRINCIPAL AGENT S&T Bank d/b!a S&T Mineral Managemenc $Y' - ---.— �Y� ____._� Date: Title: Date: �Y� ........_..----- — Dace: M Z FEE SCHEDULE Mlneral Management Agency Accotincs The fee for mineral management agency account is based on the foliowing: AnnuaE fee fcr any non-producing oil and gas royalcy incerest............................................................ $2 i Leasebonus consideration...............................................................................................................................b�o (Subjea to$1SO n;hurnum jee! Negouation o(a lease amendn�ent or ratification..............................._............._...................................$200 Per-division order or cransfer order processed...................................................................................... $50 Oil and gas interesc, royalty incerest or overriding royalty interest.....................................................6°1 tSubject ca$60 minimum(eej All other receipts, induding.buc not limiced co:........................................................................................6°l - Delay rentais •- 5huc in royalties - Sale of any oil and gas incerest -- Surface damage paymencs - RighC of way agreements - Seismic testi�ig agreei�ients - Any sectlemenc as a result of operations on pri�cipaPs iand ADDITIONAL ADMINISTRATIYE 5ERVIGE CHARGES Misc�itaneous Services (per ocarrencej Nocar•y sei-vice......................................................................................................................................................$2 Sig«ature guarantee fee.................................................................................................................................. $10 PosCage........................................................................................................................................................Variable (as assessed to S&T by shi�ping vendor) Legalfees.....................................................................................................................................................Variable (as assessed to 5&T by legu!counset} _._..._.____._._____......_.._�.__.._____�____._..._..----_...._.___..._.__.___.....__.._...._._..._.___.___._.._..._.. __._._______._....._...____......_...._..._� Accounc Holder Dace _._.. .. ._.._..._ ______..... ..____._......._..._ _____. _ __._..,..____._ ----._____.___ -----... 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L- .� F �,_ _ p - �� �Ke4 L'� s°n� _ � ,� 3{jt_ ��F '� ' •� `,� �k.,� { -P �j§ �$F�9��� �� ;'�, ., . ; ,y ..r ..x'�1it� . . $'.�?- . . ..... . .......>_ � o Mineral Management Oil & Gas Management We are pleased to provide comprehensive services that benefit our clients by handling the time-consuming and complex responsibilities associated with oil and gas management.We collaborate with each client,allowing them the opportunity to maintain their desired level of personal involvement. Through our partners,we offer the experience of managing more than 60,000 oil and gas properties across the United States. Fiduciary Responsibilities • Proactive marketing of unleased acreage • Oil &gas lease review,evaluation,and negotiation • Pipeline right-of-way and well pad site damage negotiation • Other surface use agreements • Lease amendment or ratification negotiation • Division order analysis and processing • Royalty check verification and processing • Property title and deed searches • Well proposal evaluation and advisement • Coordination with industry partners for legal counsel, engineering,geology,and appraisals S&T Mineral Management does not offer tax or legal advice.Pleose consuk your tax advisor or attorney for tax and legal advice. Mineral Management Process � �� �: , L � �� �� g� R��. Production ' Lease Offer � �Revenue;�� .� : � � � = Evaluation��� ��� �� Processin� - _, t:��"�r �� z� �� ii� � xt S�� .,. �¢�. 17 � �� � � ��� fC� I"t�� �II Ptq'� � s�l I�����1�� �Ii'i�i�i��������I II�i ..0 i � c.`� �'�t, ^,-���, � Pipel�ne� M����� �"� Agreemen�.� � Lease � � �and �� � ��MANAGEMENT � �� ��� � � � Negotiatiion�� D�„ag�=� � PROCESS � �: _.: e r ._ . .� � - Negotiatton�R �,;`° tf y� ' �ia�)�..P'j�^ . . irFF��; �;�fL��i�ll��� � �1 ��d�'����I�11i� . �'���t4�,���s1 I � � I 1�,u .;� .".:. �:.. . . . . � }r� IY`,i"s:.:-:• f I '�kzsv�, � �, ��I ��.; b " � �����V�aC� ". �+�.T���. £_ � Pacl S�t� N egot a�: �� � Negottaf�,c�, v'. R � ;�i�.. „'�' a3 Rk W psY�� 1;£"�+ �£,�7#n�? �� ����''�iq� Ii���r��,I I 4�p�� �i���ilk�'i�M�� li - , , .. . .. ,.;����.� � ��;��,������,��,����i���i,� ,�.� . � .� Marcellus Shale... a We know the drill. ; �..�,� .,.� 0 . . o Mineral Management � ,; : 800.446.0246 • stbank.com � , r���..,.a L-� ts �a�r..u.�1>�x�w� ;:;j � . . rt �.5. ` + � � _t`�' �..�o � i Charles Wesley Turiano ADDRESS: 162 State Street,Johnstown, PA 15905. Cellular Phone: (814) 322-2040 EMAIL: cturiano08Ca?verizon.net PROFESSIONAL EXPERIENCE ➢ 5&T Bank o Vice President, Director of Mineral Management, S&T Mineral Management_(November 2007 to Present) ■ Responsible for the performance and profitability of S&T Mineral Management,a division of S&T Bank. ■ S&T Mineral Management provides expert management of Oil & Gas assets for royalty owners,working interest owners, and surface landowners in seven states, primarily Pennsylvania and West Virginia. ■ Currently managing over three hundred individual client accounts, covering approximately 60,000 acres. ■ Services include: • Pro-active marketing of unleased acreage. • Evaluation and negotiation of oil &gas lease and sale agreements,farmout agreements, pipeline right-of-ways, well pad site details, and other surface damage agreements. • Processing of all revenue for clients. Currently processing over five hundred royalty checks per month. • Provide assistance and coordination of tax, estate, and financial planning for landowners. o Vice President,Trust Business Development Officer, S&T Trust (September 2005 to November 2007) ■ Focused on cultivating and maintaining relationships with sources of new Trust business, including: Estate Planning Attorneys, Accountants, Charitable Organizations, and internal 5&T Bank employees. EDUCATION ➢ Universitv of Richmond.School of Arts and Sciences-Richmond,VA(1998-2002) o Double Majors in Economics and Political Science o University of Richmond Economics Honor Society o Recipient of the National Student Athlete Day Award o Member of the University of Richmond Men's Varsity Golf Team PROFESSIONAL ACTIVITIES ➢ Member of the Pennsylvania Society,one of the nation's oldest non-profit charitable organizations. http://www.pasocietV.com ➢ Member of IPAA,the Independent Petroleum Association of America ➢ Member of NARO,the National Association of Royalty Owners PERSONAL ACTIVITIES AND ACHIEVEMENTS ➢ Eagle Scout, Boy Scouts of America (1992-1998) ➢ Member of Sunnehanna Country Club o Grounds Committee member o Sunnehanna Amateur Committee member o Currently maintain a +1 handicap ➢ Treasurer, Greater Johnstown Golf Association ➢ Member of the Elks Lodge 175,Johnstown, PA. o Chair of the Capital Improvement and Fundraising Committee EXHIBIT 8 Estate of Marv Aleene Burns Livin�Heirs: Mary Ann Burns Taylor PO Box 337 , Boiling Springs, PA 17007 Joseph Whitfield Burns PO Box 236 Boiling Springs, PA 17007 Deceased Heirs: Thomas Clark Burns surviving spouse- Mary Lee Burns 7150 Estero Boulevard, Unit 903 Fort Myers, FL 33931 surviving children- Thomas Clark Burns 928 Bay Sky Way Sea Brook,TX 77586 Timothy Martin Burns 2103 Smoky View Boulevard Powell, OH 43065 Martin Arthur Burns 368 Brown Road Wyalusing, PA 18853 Lee Ann Burns DeSaia 80 Woodside Drive Powell,OH 43065 Walter Arthur Burns surviving spouse- Ann Louise Schlatter Burns 516 Locust Street Kittanning, PA 16201 surviving children- James Scott Burns 808 Centerwood Court Brandon, FL 33511 Robin Elizabeth Burns DuBois 453 Surrena R oad Harrisville, PA 16038 Heather Jean Burns Alberth 9 Bairdford Park Road Gibsonia, PA 15044 Rachel Aleene Burns Crowley 202 Georgetown Lane Export, PA 15632 f � V _ RICHARD P. MISLITSKY, ESQUIRE . Identification No. 28123 �-, �' � One West High Street—Suite 208 � o � �-��-, ►� PO Box 1290 � � � `=�' � � -r- ,� -� ,F, :a Carlisle, PA 17013 .� �;;; f--' -.; C*1 717.241.6363 ,;: :;; '�: � � F�;� COUNSEL FOR PETITIONER -; � �_� -� .,,7 ��' <=, ..,; � -,� �,�� �" : : �.-� : � w +"... m -Y, =-a =-_ ;,�. c.-� c� c> �� In re: Estate of Mary Aleene Burns (Deceased) : IN THE COURT OF COMMON PLEA� : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS COURT DIVISION Mary Ann Burns Taylor, : NO. �i � d / ��� Petitioner/Executrix of the Estate : RULE TO SHOW CAUSE And now,this�day of � a , 2014 pursuant to C.C.R.P. 208.3(a), a Rule to Show Cause why the PETITION OF THE EXECUTRIX TO APPOINT A TRUSTEE TO MANAGE ESTATE SUB-SURFACE MINERAL RENTS AND ROYALTIES should not be granted. Petitioner,the Executrix of the Estate, shall be responsible for service upon the interested parties set forth on the attached list. Such service to include: I. This Rule to Show Cause; II. PETITION OF THE EXECUTRIX TO APPOINT A TRUSTEE TO MANAGE ESTATE SUB-SURFACE MINERAL RENTS AND ROYALTIES; III. All Exhibits to the aforesaid Petition. Service upon the interested parties shall be by Certified Mail / Return Receipt. After the Rule Returnable date set forth above, Petitioner shall file an appropriate Praecipe to list this matter for hearing, or to make this Rule absolute, whatever the case may be, and attach to such Praecipe proof of service. �� Rule Returnable 3� day of �V�� 2014 � J. ti . James H. Owen, Esquire The Old Library 200 North Jefferson Street Kittanning, PA 16201 Wendy Morris, Esquire Morris Law Firm 3461 Bonita Bay Boulevard—Suite 201 Bonita Spring, FL 34134 Joseph Whitfield Burns PO Box 236 Boiling Springs, PA 17007 Mary Lee Burns 7150 Estero Boulevard, Unit 903 Fort Myers, FL 33931 Thomas Clark Burns 928 Bay Sky Way Sea Brook, TX 77586 Timothy Martin Burns' � 2103 Smoky View Boulevard Powell, OH 43065 Martin Arthur Burns 368 Brown Road Wyalusing, PA 18853 Lee Ann Burns DeSaia 80 Woodside Drive Powell, OH 43065 Ann Louise Schlatter Burns 516 Locust Street Kittanning, PA 16201 James Scott Burns 808 Centerwood Court Brandon, FL 33511 Robin Elizabeth Burns DuBois 453 Surrena Road Harrisville, PA 16038 Heather Jean Burns Alberth 9 Bairdford Park Road Gibsonia, PA 15044 Rachel Aleene Burns Crowley 202 Georgetown Lane Export, PA 15632 . ORPHANS' COURT DIVISION . COURT OF COMMON PLEAS OF In Re: MARY ALEEN BURNS . CUMBERLAND COiJNTY . PENNSYLVANIA . N0.21-89-0865 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: OS/22/14 JUDGE'S INITIALS: MLE TIME STAMP DATE: 5/22/14 IN RE: RULE TO SHOW CAUSE ............................................................................................................................ SERVICE TO: RICHARD MISLITSKY 1 WEST HIGH ST STE208 PO BOX 1290 CARLISLE PA 17013 JAMES H OWEN 200 N JEFFERSON ST KITTANNING PA 16201 WENDY MORRIS 3461 BONITA BAY BLVD SE 201 BONITA SPRINGS FL 34134 JOSEPH WHITFIELD BURNS PO BOX 236 BOILING SPRINGS PA 17007 MARY LEE BURNS 7150 ESTERO BLVD LJNIT 903 FORT MYERS FL 33931 THOMAS CLARK BURNS 928 BAY SKY WAY SEA BROOK TX 77586 TIMOTHY MARTIN BURNS 2103 SMOKEY VIEW BOULEVARD POWELL OH 43065 MARTIN ARTHUR BURNS 368 BROWN ROAD WYALUSING PA 18853 LEE ANN BURNS DESAIA 80 WOODSIDE DR POWELL OH 43065 ANN LOUISE SCHLATTER BURNS 516 LOCUST ST KITANNING PA 16201 JAMES SCOTT BURNS 808 CENTERWOOD CRT BRANDON FL 33511 ROBIN ELIZABETH BURNS DUBOIS 453 SURRENA RD HARRISVILLE PA 16038 HEATHER JEAN BURNS ALBERTH 9 BAIRFORD PARK RD GIBSONIA PA 15044 RACHEL ALEEN BURNS CROWLEY 202 GEORGETOWN LANE EXPORT PA 15632 METHOD OF MAILING: ENVELOPES PROVIDED BY: �USPS � PETITIONER � RRR ❑JUDGE ❑ HAND DELIVERED ❑ CLERK OF ORPHANS COURT ❑ OTHER MAILED: 5/23/14 ............................................................................................................................ � � ( � Deputy Clerk of Orphans' Court