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IN THE MATTER OF THE ESTATE
OF FAY E. SOUDER, DECEASED
IN THE ORPHANS' COURT DIVISION OF
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-05-0291
ESTA TE SETTLEMENT AGREEMENT
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THIS AGREEMENT, made as of this S ~ day of August 2006,
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WITNESSETH:
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THE CIRCUMSTANCES leading to the execution of this Agreement are as fOflows:
1. Fay E. Souder (the"Decedent") died testate on 14 March 2005 at 88 years of
age, and Lindford N. Kinney qualified with the Register of \Ni!ls of Cumberland County,
Pennsylvania, as Executor (the "Executor") of the Decedent's probate estate (the "Estate").
2. Decedent's Last Will and Testament (the "Will"), which was admitted to
probate, was executed by Decedent on 8 September 2004.
3. Items SECOND, THIRD, FOURTH and FIFTH of the Decedent's Will provide
for the distribution of Decedent's tangible personal property and real property, as follows:
SECOND: I give my tangible personal property and all casualty
insurance that I am carrying on said tangible personal property to
my children who are living at my death to be divided equally among
or between them as my Executor may determine. I have complete
confidence that Executor will honor any written instructions that I
may leave with regard to said tangible personal property. Any
such property not so distributed shall be sold, and the proceeds
added to my residuary estate to pass as hereafter described, or to
be distributed as my Executor otherwise determines.
THIRD: I give and bequeath to my sister, Ruth Wevodau, jf she shall
survive me, the sum of Ten Thousand Dollars ($10,000).
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FOURTH: I give my son-in-law, Linford N. Kinney, if he shall
survive me, cash or other property equal in value to one percent
(1 %) of the value of my property listed on the inventory of my real
and personal estate filed with the Register of Wills of the county of
my residence at the time of my death.
FIFTH: I presently own a tract of real property, which was formerly
a part of the farm owned by my late husband and me, situate
adjacent to the West boundary of the right-of-way of Pennsylvania
Interstate Route 581 northwest of the Creekview Road
interchange, on which is erected a communications tower, which
real property was leased by my husband and me to United
Telespectrum, Inc. ("United Telespectrum"), now to its successors
and assigns ("said lease"). Said lease provides payments to me in
monthly installments, as adjusted periodically as set forth in said
lease, and the lease has several options for renewal. At the time
of my death, I direct my Executor and Trustee, hereinafter named,
to establish a trust, the res of which shall be the land on which the
United Telespectrum tower is erected, and all lease payments
thereafter on account of the rental thereof under said lease shall
be paid to the Trustee and held in trust. The monthly iease pay-
ments shall be invested by my Trustee as my Trustee, in his or its
sole discretion, determines shall be appropriate and the net income
from that trust, including all interest earned from the investment of
the periodic lease payments, shall be distributed once annually in
each December in equal shares to my four children, or their benefi-
ciaries as set forth in Items SIXTH (1) through (4) inclusive hereaf-
ter. If any of my said children fail to survive me, then their respec-
tive share shall be distributed to their respective beneficiaries as
set forth for each of them in Items SIXTH (1) through (4) inclusive
hereafter. At the termination of said lease, in the event United
Telespectrum or its then successor and assigns elects not to reach
an agreement with the Trustee to purchase the real property on
which the tower is erected, then my Trustee shall proceed to sell or
otherwise dispose of said real property and distribute the proceeds
therefrom equally among my children or their respective beneficia-
ries as set forth in Items SIXTH (1) through (4) inclusive hereafter,
and the trust shall thereupon terminate.
4. Item SIXTH of the Decedent's Will provides for the distribution of the rest,
residue and remainder of Decedent's property, as foliows:
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SIXTH: I give, devise and bequeath the rest, residue and
remainder of my estate, real and personal, which thereupon shall
be divided into four equal shares and distributed as follows:
(1) One share to my son, Ray M. Souder, Jr., if living. If he
is not then living, his share shall be divided into two
separate and equal shares, one share to be distributed
outright to Ray's son, Steven, and the other share to be
held in trust for the benefit of Ray's son, Gregory. The
Trustee shall distribute annually to Gregory all net in-
come from the Trust, together with an annual contribution
of ten percent (10%) of the principal in said Trust at its
inception, so that the principal of said Trust shall be
exhausted after ten years from inception and thereupon
terminated. In the event, Gregory dies prior to distribu-
tion of all funds from the trust for his benefit, the remain-
ing principal and income shall continue to be paid on the
ten year installment basis to his issue. If Gregory dies
without issue, then the remaining funds held in trust for
him shall be distributed outright to his brother, Steven, or
his issue.
(2) One share to my daughter, Joyce A. Kinney, if living. If
she is not then living, her share shall be given to her
daughter, Janet.
(3) One share to my daughter, Shirley Ann Snyder. If she is
not then living, her share shall be distributed to her hus-
band, Jerome Snyder.
(4) One share to my son, Paul H. Souder, if living. If he is
not then living, his share shall be divided into two sepa-
rate and equal shares, a one-half share to his wife, Al-
berta, and one-half share to his son, Michael, or to the
survivor of them.
(5) If at the time of my death, or at any later time prior to
final distribution hereunder, my children and all persons
named in Items SIXTH (1) through (4) inclusive are de-
ceased and no other disposition of the property is di-
rected by this Will, then and in that event only, the then-
remaining principal of this Will and of any Trust created
hereunder, together with any undistributed income, shall
be divided and paid over and distributed one-half (IS) to
those persons then living who would then be my heirs,
their identities and respective shares to be determined in
accordance with the law then in effect in the Common-
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wealth of Pennsylvania, as if I had then died intestate,
and one-half (";/z) to those persons then living who would
then be my late husband's heirs, their identities and
respective shares to be determined in accordance with
the law then in effect in the Commonwealth of Pennsyl-
vania, as if he had then died intestate.
(6) Except as otherwise provided herein, if any share here-
under becomes distributable to a beneficiary who has not
attained the age of twenty-five (25) years, then such
share shall immediately vest in such beneficiary, but
notwithstanding the provisions herein, my Trustee shall
retain possession of such share in trust for such benefi-
ciary until such beneficiary attains the age of twenty-five
(25) years, using so much of the net income and princi-
pal of such share as my Trustee deems necessary to
provide for the proper medical care, education, support
and maintenance of such beneficiary, taking into consid-
eration to the extent my Trustee deems advisable any
other income or resources of such beneficiary or his or
her parents known to my Trustee. Any income not so
paid or applied shall accumulate and be added to princi-
pal. Such beneficiary's share shall be paid over and
distributed to such beneficiary upon attaining the age of
twenty-five (25) years, or, if he or she shall sooner die, to
his or her executors or administrators. I recommend that
my Trustee consider distributing periodically all income
from such share to such beneficiary after such benefi-
ciary attains the age of twenty-one (21) years.
5. The Beneficiaries desire to settle the Estate informally in order to avoid the
expense and delay involved with the formal adjudication of a First and Final Account by the
Orphans' Court Division of the Court of Common Pleas of Cumberland County, Pennsylva-
nia (the "Court").
6. The Executor joins in this p.,greement to signify his agreement with the terms
hereof as more particularly set forth hereafter.
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7. The Beneficiaries and Executor desire to forever settle and compromise any
and all claims and rights which they may possess, now or hereafter, in the Estate and to
confirm their acceptance of the Informal Account (the "Account"), attached hereto as
Exhibit "A" and incorporated herein by this reference, and the Schedule of Proposed
Distribution (the "Schedule"), attached hereto as Exhibit "B" and incorporated herein by
this reference. The Beneficiaries and Executor desire that the distributions to the Benefi-
ciaries, as set forth in Exhibit "B", be in full satisfaction of their rights in the Estate.
8. The Beneficiaries wish to release the Executor and to indemnify him against
any and all claims that may be asserted against the Estate or the Executor after the date
hereof. The Beneficiaries also desire to release the Executor with respect to the waiver of
a right to a formal adjudication of a First and Final Account of the Estate.
9. The Executor is willing to settle the Estate informally in consideration of
the indemnifications hereinafter provided by the Beneficiaries and Trustee.
NOW THEREFORE, in consideration of the foregoing and intending to be legally
bound, the Beneficiaries and Executor, for themselves, their heirs, personal representa-
tives, successors and assigns:
1. Represent and warrant that they have read and understand this Agreement
and confirm that the facts set forth above are true and correct, to the best of
their knowledge, information and belief.
2. Declare that they have sufficient information to make an informed waiver of
their right to a formal accounting with the Court, and they do hereby waive the
filing and auditing of the same.
3. Acknowledge that the distributive share or amount set forth on the Schedule
shall be in full satisfaction of the Beneficiaries' entitlements under the Will.
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4. Release, remise, quitclaim and forever discharge the Executor, his heirs,
personal representatives, successors and assigns, from and against all claims
that they may, as legatees of the Estate, and in connection with the Estate,
have, had, now has or may in the future have in connection with the Estate.
5. Agree to refund, on demand, all or any part of any aforesaid distribution, which
has been determined by the Executor, or by the Court, or by any cOLlrt of
competent jurisdiction, to have been improperly made.
6. Agree to indemnify and hold harmless the Executor, his heirs, personal
representatives, successors and assigns, from and against any and all claims,
loss, liability or damage (whether or not related to the negligence of the
Executor) that may hereafter be asserted against the Estate or against the
Executor.
7. Agree to execute such other or additional documents as may be necessary to
effectuate the agreements set forth herein.
8. Acknowledge that this Agreement shall be governed by and construed in
accordance with the laws of the Commonwealth of Pennsylvania.
9. Consent to the Court exercising personal jurisdiction over the Beneficiaries in
any suit or action arising out of the enforcement of this Agreement.
IN WITNESS WHEREOF, the Executor and the Beneficiaries have placed their
hands and seals on the attached Consents to Estate Settlement Agreement.
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CONSENT TO ESTATE SETTLEMENT AGREEMENT
AND RECEIPT OF DISTRIBUTION
I, LINFORD N. KINNEY, individually and as an Executor of the Estate of Fay E.
Souder and as Trustee of the Trust Under Will of Fay E. Souder, created therein, hereby
acknowledge, as Executor, causing distribution of and, individually and as Executor of the
Estate of Fay E. Souder and Trustee of the Trust Under Will of Fay E. Souder, acknowl-
edge receipt of the assets of the Estate of Fay E. Souder, as set forth in the attached
Estate Settlement Agreement, and I, individually and in my fiduciary capacities, hereby
consent to and join in the Estate Settlement Agreement, including Exhibits, which has been
provided to me.
WITNESS
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COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
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On this, the ~ - day of August 2006, before me, the undersigned officer,
personally appeared LINFORD N. KINNEY, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same in the capacities and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunde~\ ~~~ ~eal
Notary Public
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NO i\RI L SEAL
MICHELLE E. 80 E MILLER, Notary Public
Camp Hill Bora., Cumberland County
My Commission .~pir"'~ I\!O\l~.m.b.~~3, 2006
CONSENT TO ESTATE SETTLEMENT AGREEMENT
AND RECEIPT OF DISTRIBUTION
I, SHIRLEY ANN SNYDER, hereby acknowledge receipt of the assets of the Estate
of Fay F. Souder, as set forth in the attached Estate Settlement Agreement, and I hereby
consent to and join in the Estate Settlement Agreement, including Exhibits, which has been
provided to me.
WITNESS
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SHIRLEY A N SNYDER
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF
cL.
On this, the 5- day of August 2006, before me, the undersigned officer,
personally appeared SHIRLEY ANN SNYDER, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same in the capacities and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunde~ ~~~~ seal. ~ \ ~
Notary Public
OT RIAL SEAL I
MICHELLE E. ER MillER, Notary Public
Camp HillBoro. Cumberla'1d County ,
My Commission E~r;'u. 11.20q~J
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CONSENT TO ESTATE SETTLEMENT AGREEMENT
AND RECEIPT OF DISTRIBUTION
I, PAUL H. SOUDER, hereby acknowledge receipt of the assets of the Estate of Fay
E. Souder, as set forth in the attached Estate Settlement Agreement, and I hereby consent
to and join in the Estate Settlement Agreement, including Exhibits, which has been
provided to me.
WITNESS
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PAUL H. SOUDER
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF
L
On this, the ::;- - day of August 2006, before me, the undersigned officer,
personally appeared PAUL H. SOUDER, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that he
executed the same in the capacities and for the purposes therein contained.
IN WITNESS WHEREOF, I hereund~~ ~~~~eal
Notary Public
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N AlSEAl . 11
MiCHELLE E. BOYER MillER, Nc~ary PubliC I
Camp Hill Boro., Cumberland County i
r-Ay Commissi~n ~~pir('.:,..~~o!(J,;nht':'f.~3:_?QQ?..:
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CONSENT TO ESTATE SETTLEMENT AGREEMENT
AND RECEIPT OF DISTRIBUTION
I, JOYCE A. KINNEY, hereby acknowledge receipt of the assets of the Estate of
Fay E. Souder, as set forth in the attached Estate Settlement Agreement, and I hereby
consent to and join in the Estate Settlement Agreement, including Exhibits, which has been
provided to me.
JO
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WITNESS
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COMMONWEALTH OF PENNSYLVANIA
55.
COUNTY OF
J.-
On this, the 5 - day of August 2006, before me, the undersigned officer,
personally appeared JOYCE A. KINNEY, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that she
executed the same in the capacities and for the purposes therein contained.
IN WITNESS WHEREOF, I hereund~~~~ ~ffiCial seal,
Notary Public
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CONSENT TO ESTATE SETTLEMENT AGREEMENT
AND RECEIPT OF DISTRIBUTION
I, RAY M. SOUDER, JR., hereby acknowledge receipt of the assets of the Estate of
Fay E. Souder, as set forth in the attached Estate Settlement Agreement, and I hereby
consent to and join in the Estate Settlement Agreement, including Exhibits, which has been
provided to me.
WITNESS
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RAY M. S DER, JR. tf
COMMONWEAL TH OF PENNSYLVANIA
S5.
COUNTY OF
~
On this, the 5 - day of August 2006, before me, the undersigned officer,
personally appeared RAY M. SOUDER, JR., known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same in the capacities and for the purposes therein contained.
IN WITNESS WHEREOF, I hereunder set my han and official seal.
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Notary Public
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NOT IAl SEAL
MICHELLE E. BOYER MillER, Notary Public
Camp Hill BOfO., Cumberland County
My COITlft1ission Expirps_~.o\I~~b~U1: 2006
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EXHIBIT A
INFORMAL ACCOUNT OF THE EXECUTOR
Date of Death:
March 14, 2005
Accounting for Period:
March 14, 2005 through
July 31, 2006
ESTA TE OF FA Y E. SOUDER
ASSETS AND EXPENSES
ESTA TE ASSETS:
Locust Lane, Mechanicsburg Property
The Vanguard Group - investment account
Mortgage from Michael E. Souder
PA State Bank - checking account
PA State Bank - savings account
$ 104,774.48
665,623.85
11,613.12
45,476.55
228,964.26
TOTAL ESTATE ASSETS $ 1,047,560.35
EXPENSES PAID FROM THE ESTA TE:
$ 9,631.82
3,095.00
172.10
457.33
361 .74
1 ,108.11
241.50
108.03
224.20
35.00
764.00
6,628.18
42.00
170.00
47,843.56
10,000.00
15,000.00
TOTAL EXPENSES PAID $ 95,882.57
Malpezzi Funeral Home
Loyalton of Creekview
Newspaper Notices
Meal after funeral
Medical bills received after death
Cellular tower 2005 real property taxes
Sewer and trash for Locust Lane property
Electric bills for Locust Lane property
Water bills for Locust Lane property
Short certificates/filing fees
Probate Fees
Loss from damage to Locust Lane property
2005 Federal estate income tax
2005 Pennsylvania estate income tax
P A Inheritance tax
Bequest to Ruth E. Wevodau
Legal fees
AMOUNT TO BE DISTRIBUTED $ 951.677.78
ESTATE OF FA Y E. SOUDER
PROPOSED D/STRUBUTION
BALANCE REMAINING
PROPOSED DISTRIBUTIONS:
Expenses Remaining:
Miller & Associates, PC - legal fees/out-of-pocket
Linford N. Kinney, Executor's Fee
Cumberland County Register of Wills - filing fee
Reserve for future taxes and miscellaneous expenses
$ 951,667.78
$ 10,500.00
10,000.00
20.00
5,000.00*
Expenses Remaining
Beneficiary Distributions:
(25,520.00)
$ 11,043.72
665,623.85**
249,490.21
Linford N. Kinney - 1 % of value of the estate
The Vanguard Account - split equally by four siblings
Cash Distributions:
Ray M. Souder, Jr. - $65,275.83
Joyce N. Kinney - $65,275.83
Shirley Ann Snyder - $65,275.84
Paul H. Souder - $65,275.83 - $11,613.12 = $53,662.71
Beneficiary Distributions
(926,157.78)
TOTAL PROPOSED DISTRIBUTIONS $ 951,677.78
BALANCE REMAINING IN ESTATE $ 0.00
*Any amount remaining after all estate expenses have been paid will be
distributed equally to the beneficiaries.
**This amount may change due to changes in market value.