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HomeMy WebLinkAbout01-14-04 .. J..t .. ~ INRE: ESTATE OF LOY T. HEMPT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-77-231 ORPHANS' COURT DIVISION KALBACH OBJECTORS' PRE-TRIAL MEMORANDUM I. SUMMARY CASE OVERVIEW Gerald L. Hempt is simultaneously the Trustee of the Loy T. Hempt Residuary Trust, a remainder beneficiary of the Trust, Guardian of the Estate and Person of Jean D. Hempt and a Beneficiary of the Jean Hempt Estate. Gerald Hempt was appointed Trustee of the Loy T. Hempt Residuary Trust without notice to the remainder beneficiaries and in proceedings which did not identify the Loy T. Hempt Trust or Loy T. Hempt Estate in the caption or docket numbers. Gerald Hempt has multiple conflicts of interest. He has an antagonistic relationship with a remainder beneficiary, Robert Kalbach. Finally, and most importantly, Gerald Hempt, as Trustee, has engaged in a pattern of conduct for his personal benefit that violates his fiduciary obligations to remainder beneficiaries and constitutes an abuse of his discretion. As Trustee of the Loy T. Hempt Residuary Trust, Gerald Hempt has purportedly divided the Trust into three (3) trusts, one for the benefit of his family (40%), one for the benefit of the Mark family (40%) and one for the benefit of the Kalbach family (20%). He then manipulated the valuation and allocation of Trust assets into the separate trusts so that he could obtain those specific Trust assets he desired (closely held family business interests), while simultaneously .. , , depriving those Trust assets from another remainder beneficiary, Robert Kalbach. These actions, purportedly as Trustee, were implemented solely for his personal benefit and the benefit of his close family members, to the detriment of Robert Kalbach, and constitute a most egregious abuse of discretion and violation of his fiduciary obligations. Further, since becoming Trustee in 1996, Gerald Hempt continued the practice of the prior trustee (his father, Max Hempt) of distributing assets of the Loy T. Hempt Residuary Trust to the Estate of Jean Hempt, knowing full well that Jean Hempt (who is an adjudged incapacitated person in a custodial living arrangement) had (and has) assets well in excess of those needed for her to live in her customary manner. After making these distributions for years, Gerald Hempt, wearing the hat of the Guardian of the Estate of Jean D. Hempt, then petitioned this Court for permission to make gifts from the Jean Hempt Estate to himself and the other Jean Hempt Estate beneficiaries, asserting that Jean had more than enough assets for her to live in her customary manner and that a gifting program was appropriate. This funneling of funds from the Loy T. Hempt Residuary Trust to the Jean Hempt Estate deprived Robert Kalbach of twenty (20%) percent of the transferred assets since he is a remainder beneficiary of the Loy T. Hempt Trust but is not a beneficiary of the Jean Hempt Estate. Under these circumstances the Kalbach Objections to the Accounting must be sustained and the relief requested therein be granted. Most importantly, Gerald Hempt must be removed as Trustee of the Loy T. Hempt Residuary Trust, the Loy T. Hempt Residuary Trust must be reconstituted as a single trust from the separate trusts allegedly created by Gerald Hempt, and 2 J. ' 1 finally, Gerald Hempt must be surcharged those distributions made from the Loy T. Hempt Residuary Trust to the Jean Hempt Estate so that the Loy T. Hempt Residuary Trust is made whole. II. POTENTIAL WITNESSES 1. Robert Kalbach 2. Robert Kalbach, Jr. 3. Richard Kalbach 4. Gerald Hempt 5. George Hempt 6. Robert Freedman, Esquire 7. W. Robert Mark 8. Forrest H. Mark 9. Steven E. Mark Expert Witness 1. John Stoner, CPA, CV A III. POTENTIAL EXHIBITS. 1. Loy T. Hempt Will dated December 8, 1964 and a Codicil dated December 12, 1969. 2. Hempt family tree. 3. Proceedings docket for the Loy T. Hempt Estate. I The parties have entered into a confidentiality agreement which encompasses many of these potential exhibits. A procedure should be discussed whereby confidentiality of these documents, if deemed necessary, is maintained during these proceedings. 3 .; , 4. Petition for Appointment of Successor Trustee and Successor Guardian of the Estate and Person in "In the Matter of Jean Doris Hempt, an Incompetent," filed on or about July 3, 1996, including Final Decree dated September 3, 1996. 5. Petition for Appointment of Successor Co-Trustee and Successor Co-Guardian of Estate and Person in "In Re: Estate of Jean Doris Hempt, an Incompetent Person," filed on or about May 18, 2001. 6. Petition for Permission to Make Gifts Pursuant to Section 5536(b), Probate, Estates and Fiduciaries Code in "In Re: Estate of Jean Doris Hempt, an Incompetent Person," filed on or about May 18, 2001. 7. Jean D. Hempt expenses and income summary prepared by Accounting Party. 8. Jean D. Hempt Form 1040, federal tax returns for 1982 - 2002. 9. Chart of Jean Hempt annual income from other sources outside Loy's Trust per income tax returns. 10. Merrill Lynch portfolio summary review for Jean D. Hempt Trust as of May 30, 2003. 4 ; 'r 11. 1,2001. Limited Summary Appraisal Report for Valley Land Company, Inc. dated January 12. December 31, 2000 valuation report for C.A. Hempt Estate, Inc. 13. C.A. Hempt Estate, Inc. valuation letter from Robert Freedman, Esquire dated August 21,2001.. 14. Hempt Brothers, Inc. Buy-Sell Agreement. 15. 7,2001. Compass Capital Partners, Ltd. valuation of Hempt Brothers, Inc. dated December 16. Valuation methodology of Hempt Brothers, Inc., contained in Form 706 for the Estate of Max C. Hempt. 17. Letter from Robert Freedman, Esquire to Gerald L. Hempt and George F. Hempt dated March 1, 2001. 18. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated March 21,2001. 19. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated April 11, 2001. 5 .; 20. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated May 7., 2001. 21. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated May 15,2001. 22. Letter from Robert Freedman, Esquire to Gerald L. Hempt and George F. Hempt dated May 15,2001. 23. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated April 23, 2002. 24. Letter from Robert Freedman, Esquire to Gerald L. Hempt dated July 12, 2002. 25. Various documents relating to the valuation of Hempt Brothers, Inc. by the Kalbach Objectors' expert witness, John Stoner, were reviewed and relied upon. The Kalbach Objectors do not believe that all of these documents need to be matters of record in these proceedings. However, Kalbach Objectors reserve the right to utilize any of these documents as necessary . 26. Kalbach Objectors .believe that the Accounting, Petition for Adjudication, Kalbach Objections and Mark Objections are already filed as documents of record and do not need to be introduced as separate exhibits in these proceedings. 6 j IV. PROPOSED STIPULATIONS2 1. Loy T. Hempt died on March 19, 1977. 2. Loy T. Hempt made a Will dated December 9, 1964 and one Codicil dated December 12, 1969. 3. Loy T. Hempt's Codicil appointed Max C. Hempt and Margaret Hempt as trustees of the trust created under Item Fifth of his Will (the "Loy Hempt Residuary Trust"). 4. ITEM FIFTH of the Loy Hempt Residuary Trust states, in pertinent part: "FIFTH: I devise and bequeath all the rest of my estate, of whatever kind and whatever situate, to my trustees hereinafter named, in trust as follows: (1) During such time as either or both of my wife, Margaret, and my niece, Jean Hempt, are living, trustees shall pay to or expend directly for the benefit of either or both of my wife and my niece such parts or all or none of the net income and principal as trustees may determine in their sole and absolute discretion, to provide for their care, support, and welfare, . . . (2) Upon the death of the survivor of my wife, Margaret, and my niece, Jean Hempt, . . . trustees shall transfer the remaining principal as follows: (a) Forty (40%) percent thereof to my nephew, Max C. Hempt, ifhe is then living, but if he 2 These proposed stipulations are currently being reviewed for accuracy by the Kalbach Objectors and are submitted for consideration with the qualification that this review could result in modification. 7 ~ ~ is then dead, to his then living issue, per stirpes. (b) Forty (40%) percent thereof to my niece, Dorothy Mark, if she is then living, but if she is then dead, to her then living issue, per stirpes. (c) Twenty (20%) percent thereof to my nephew, Robert Kalbach, ifhe is then living, but if he is then dead, to his then living issue, per stirpes." 5. Jean D. Hempt was Loy T. Hempt's niece. 6. Max C. Hempt was Loy T. Hempt's nephew. 7. Margaret Hempt was Loy T. Hempt's wife and she died in 1988. 8. When Margaret Hempt died in 1988, Dorothy Hempt, Loy Hempt's niece, became the successor co-trustee pursuant to the Codicil. 9. Dorothy Hempt, a/k/a Dorothy H. Mark, was the mother of W. Robert Mark, Forrest H. Mark and Steven E. Mark. 10. When Dorothy Hempt died in 1995, Max Hempt became the sole trustee of the Loy T. Hempt Residuary Trust. 8 I> ~ 11. Max C. Hempt, a remainderman of the Loy T. Hempt Residuary Trust, died on May 3, 1999 survived by his children, Gerald L. Hempt, George F. Hempt, Martha H. Bair and Marian H. Semoff. 12. Dorothy Mark, a remainderman of the Loy T. Hempt Residuary Trust, died on June 15, 1995 survived by her three children, Robert Mark, Forrest Mark and Steven Mark. 13. Robert Kalbach, a remainderman of the Loy T. Hempt Residuary Trust, survives today, as do his two children, Robert Kalbach, Jr. and Richard Kalbach. 14. Jean Doris Hempt was born on January 24, 1927 and, because of her disability, she has since September 13, 1938 been a resident at The Woods School and Residential Treatment Center, Langhorne, Pennsylvania, a private facility. 15. Jean Doris Hempt is unmarried and has no children. Her parents are deceased. 16. By Final Decree of the Court of Common Pleas of Cumberland County, Pennsylvania dated March 8, 1985, entered to No. 117 Orphans 1985, Jean Doris Hempt was adjudged an incompetent and Max C. Hempt and Dorothy H. Mark were appointed guardians of Jean's estate, with no bond required. 9 \0 17. By Final Decree of the Cumberland County Court, dated Mary 10, 1990, Max C. Hempt and Dorothy H. Mark were appointed guardians of the person of Jean, with no bond required. 18. It is anticipated that Jean Doris Hempt will, during the balance of her life, continue to reside at The Woods School and Residential Treatment Center. 19. Jean Doris Hempt had two siblings, Dorothy H. Mark and Max C. Hempt. 20. Because of her incompetency, Jean Doris Hempt never had and never will have the capacity to make a valid will. The assets held in her guardianship account will pass to her intestate heirs upon her death. 21. The intestate heirs of Jean Doris Hempt are the surviving children of Max C. Hempt and Dorothy H. Mark. Specifically, her next of kin are as follows: Issue of Max C. Hempt Issue of Dorothy H. Mark George F. Hempt Gerald L. Hempt Marian H. Semoff Martha D. Bair W. Robert Mark Forrest H. Mark Steven E. Mark 22. Robert Kalbach is not an intestate heir of Jean Doris Hempt and is entitled to no proceeds of her estate upon her death. 10 if 23. In early July, 1996, Max C. Hempt and Gerald L. Hempt filed a Petition for Appointment of Successor Trustee and Successor Guardian of Estate and of Person in the Court of Common Pleas, Cumberland County, Pennsylvania (the "1996 Co-Guardianship Petition"). 24. The 1996 Co-Guardianship Petition was captioned only "In the Matter of Jean Doris Hempt, an Incompetent." 25. The 1996 Co-Guardianship Petition only references the following docket numbers: No. 2008 of 1942, which is the will of Jean's father, George L. Hempt, in the Office of the Register of Wills of Cumberland County. No. 253 of 1977, which is the proceeding in the matter of the testamentary trust under the Will of George L. Hempt for the benefit of Jean. No. 117 of 1985, Orphans' Court Division, the proceeding adjudicating Jean Doris Hempt an incompetent and appointing Max C. Hempt and Dorothy H. Mark guardians of her estate. 26. The 1996 Co-Guardianship Petition does not reference any of the docket numbers for the Estate ofLoy T. Hempt or the trust under the will ofLoy T. Hempt, which is Estate No. 21-77-231. 27. Notice of the filing of the 1996 Co-Guardianship Petition was not provided to Robert H. Kalbach, Sr. or to his sons, Richard C. Kalbach and Robert H. Kalbach, Jr. 11 ., 28. Notice of the filing of the 1996 Co-Guardianship Petition was not provided to Robert W. Mark, Forrest H. Mark or Steven E. Mark. 29. The Final Decree signed by the Honorable Harold E. Sheeley in response to the 1996 Co-Guardianship Petition purports to appoint Gerald L. Hempt as a co-trustee with Max C. Hempt of the testamentary trust for the benefit of Jean Doris Hempt under the will ofLoy T. Hempt. 30. By Decree of the Court of Common Pleas of Cumberland County dated September 3, 1996, Gerald Hempt was appointed as Co-Guardian (with his father, Max C. Hempt) of the estate and of the person of Jean Hempt. 31. Since Max Hempt's death on May 23, 1999, Gerald L. Hempt has been sole Guardian of the estate and of the person of Jean Hempt. 32. In a "Petition for Appointment of Successor Co-Trustee and Successor Co- Guardian of Estate and Person" filed in the Court of Common Pleas of Cumberland County on or about May 18,2001, Gerald L. Hempt and his brother, George F. Hempt, sought, inter alia, to have George F. Hempt appointed as Co-Guardian (with Gerald L. Hempt) of the estate and of the person of Jean Hempt (the "2001 Co-Guardianship Petition"). 12 .. i 33. The 2001 Co-Guardianship Petition was captioned only "IN RE: ESTATE OF JEAN DORIS HEMPT, an Incompetent Person" and was docketed only to No. 117 ORPHANS' 1985. 34. The 2001 Co-Guardianship Petition also sought to have George F. Hempt appointed as co-trustee of the Loy T. Hempt Residuary Trust. 35. The Co-Guardianship Petition was not docketed or indexed in any docket relating to the Loy T. Hempt Estate or the Loy T. Hempt Residuary Trust. 36. Advance notice of the filing of the 2001 Co-Guardianship Petition was provided to Marian D. Semoff, Martha D. Bair, Forrest H. Mark, W. Robert Mark and Steven E. Mark. 37. No notice of the filing of the 2001 Co-Guardianship Petition was provided to Robert H. Kalbach, Sr., Robert H. Kalbach, Jr., or Richard C. Kalbach. 38. Advancement of the Co-Guardianship Petition has been stayed by agreement. 39. The value of the Jean Doris Hempt Estate as of May 30, 2003, is approximately One Million Nine Hundred Thirty-Seven Thousand Four Hundred Sixty-Nine ($1,937,469.00) Dollars, not including her shares of Hempt Brothers, Inc. ("Hempt Brothers") and C.A. Hempt Estates, Inc. ("C.A. Hempt Estate"), closely-held family businesses. 13 '" .' 40. The Jean Hempt Estate owns 1,547 shares of Hempt Brothers stock. 41. Both Gerald L. Hempt and George G. Hempt are significant shareholders of Hempt Brothers. 42. Both Gerald L. Hempt and George F. Hempt are officers of Hempt Brothers and are actively involved in the management and operation of Hempt Brothers. 43. A valuation of Hempt Brothers stock was performed by Compass Capital Partners, Ltd. in 2001 (the "Compass Valuation") at the request of George Hempt, President of Hempt Brothers. 44. The Compass Valuation valued the Hempt Brothers stock at $643.49 per share as of August 31,2001. 45. The value of the Jean Hempt Estate's Hempt Brothers stock, based solely on the Compass Valuation, was $995,479.03 as of August 31, 2001. 46. The Jean Hempt Estate owns 2,000 shares of C.A. Hempt Estate. 14 ~ .' 47. The other shares ofC.A. Hempt Estate are owned as follows: Robert Kalbach Trust FBO Martha D. Hempt Gerald Hempt George Hempt Robert Mark Forrest Mark Steven Mark Loy Hempt Residuary Trust 6,000 shares 2,000 shares 3,000 shares 3,000 shares 667 shares 667 shares 666 shares 6,000 shares 48. For purposes of a purported trust division as of April 25, 2002, Gerald L. Hempt, the purported trustee of the Loy T. Hempt Residuary Trust, who is also the guardian of the Jean Hempt Estate, valued a share of C.A. Hempt Estate at $104 (the "Trustee Valuation"). 49. The value of the C.A. Hempt Estate stock owned by the Jean Hempt Estate, based solely on the Trustee Valuation, is $208,000. 50. The value of the Jean Hempt Estate, based solely on the valuations identified herein, is $3,140,948. 51. The costs of residential care for Jean Doris Hempt at The Woods School and Residential Treatment Center for the five years ending 2001 are as follows: 15 - ..' 1997 - $43,795 1998 - $48,096 1999 - $49,170 2000 - $58,601 2001 - $54,300 52. Jean Doris Hempt has assets well in excess of those needed for her to live in her customary manner. 53. On or about May 18,2001, Gerald L. Hempt and George F. Hempt, purporting to be Guardians of the Estate of Jean Doris Hempt, filed a petition in the Court of Common Pleas of Cumberland County entitled "Petition for Permission to Make Gifts Pursuant to Section 5536(b), Probate, Estate and Fiduciaries Code (the "Petition to Make Gifts"). In the Petition to Make Gifts, George F. Hempt and Gerald L. Hempt allege that, "If Jean Doris Hempt was able to use her judgment, Petitioners believe she would make lifetime gifts to her intestate heirs." 54. No notice of the filing of the Petition to Make Gifts was provided to Robert H. Kalbach or his sons. 55. In the Petition to Make Gifts, Petitioners further requested that the Court authorize them as Guardians of the Estate of Jean Doris Hempt ''to make outright gifts in the amount ofTen Thousand ($10,000.00) Dollars per year to each of the seven (7) intestate heirs of Jean Doris Hempt. Specifically, the current intestate heirs are the four (4) surviving children of 16 " t' her brother, Max C. Hempt, and the three surviving children of her sister, Doris Hempt Mark, all seven (7) of whom would share per capita her estate upon her death." 56. In the Petition to Make Gifts, Gerald L. Hempt and George F. Hempt further requested "that the Court approve a plan of annual giving beginning retroactively in 2000 and continuing until Jean Doris Hempt's death, which said plan will authorize Petitioners (in their capacity as Guardians of the Estate of Jean Doris Hempt) to make annual gifts in the amount of Ten Thousand ($10,000.00) Dollars to each of the above-described nephews and nieces of Jean Doris Hempt." 57. In the Petition to Make Gifts, George F. Hempt and Gerald L. Hempt further "request this Court to approve a one-time gift to her nieces and nephews of Jean Doris Hempt in the amount of Six Hundred Seventy-Five Thousand ($675,000.00) Dollars. 58. Upon the death of Jean Hempt, the assets of her estate will be distributed in equal shares to her intestate heirs, George F. Hempt, Gerald L. Hempt, Marian H. Semoff, Martha D. Bair, W. Robert Mark, Forrest H. Mark and Steven E. Mark. 59. Upon the death of Jean Hempt, the Loy T. Hempt Residuary Trust will terminate, and by its provisions the assets will be distributed forty (40%) percent to the issue of Max C. Hempt (George F. Hempt, Gerald L. Hempt, Marian H. Semoff and Martha D. Bair), forty (40%) 17 '" .. percent to the issue of Dorothy Mark (W. Robert Mark, Forrest H. Mark and Steven E. Mark) and twenty (20%) percent to Robert H. Kalbach. 60. Whether assets are distributed from the Loy T. Hempt Residuary Trust or from the Jean Hempt Estate upon the death of Jean Hempt has a direct financial impact on Robert H. Kalbach since he would receive 20% of the assets of the Loy T. Hempt Residuary Trust, whereas he would receive nothing if those assets were instead distributed from the Jean Hempt Estate. 61. Assets of the Loy T. Hempt Residuary Trust include two thousand one hundred thirty-two (2,132) shares of stock in Hempt Brothers, Inc., a closely-held family business. 62. Assets of the Loy T.Hempt Residuary Trust include six thousand (6,000) shares of stock in C.A. Hempt Estate, Inc., a closely-held family business. 63. Assets of the Loy T. Hempt Residuary Trust include eighty-nine (89) shares of common stock in Valley Land Co. out of a total of one hundred (100) shares of common stock of Valley Land Co. issued and outstanding, a closely-held family business. 64. The remaining eleven (11) shares of Valley Land Co. common stock are owned by Gerald L. Hempt. 18 . f 65. If the Loy T. Hempt Residuary Trust had not been divided, after the death of Jean Hempt the stock of Valley Land would be held as follows: Robert H. Kalbach Mark Brothers Objectors' Shares Gerald L. Hempt Gerald L. Hempt Siblings Hempt Family Shares Total Shares 17.8 shares 35.6 shares 53.4 shares 19.9 shares 26.7 shares 46.6 shares 100.0 shares 66. If the Loy T. Hempt Residuary Trust had not been divided, after the death of Jean Hempt the stock of C.A. Hempt Estate would be held as follows: Robert H. Kalbach Mark Brothers Objectors' Shares Max Hempt Children's and Widow's Shares Total Shares 7,200.00 shares 5.257.14 shares 12,457.14 shares 11.542.86 shares 11.542.86 shares 24,000.00 shares 67. By document dated April 25, 2002, Gerald L. Hempt, purported Trustee of the Loy T. Hempt Residuary Trust, purported to divide the Loy T. Hempt Residuary Trust into three (3) separate trusts, one for the benefit of the issue of Max Hempt, the second for the benefit of the issue of Dorothy Mark and the third for the benefit of Robert H. Kalbach. 19 - ;, 68. Gerald L. Hempt is, simultaneously, purported Trustee of the Loy T. Hempt Residuary Trust, a beneficiary of the Loy T. Hempt Residuary Trust, Guardian of the Jean Hempt Estate, and a beneficiary of the Jean Hempt Estate. 69. Gerald L. Hempt, with his father Max, from 1996 to 1999 and solely since 1999, has controlled the distribution of assets from the Loy T. Hempt Residuary Trust to the Jean Hempt estate. 70. During the five (5) years preceding and including 2001 (the same year Gerald L. Hempt requested the Court to approve distributions exceeding $800,000 from the Jean Hempt Estate to himself, his siblings and his Mark cousins), Gerald L. Hempt directed the transfer of $315,000 from the Loy T. Hempt Residuary Trust to the Jean Hempt Estate. 71. Gerald L. Hempt received and relied upon the advice of legal counsel, Robert L. Freedman, Esquire, to divide and distribute the assets of the Loy T. Hempt Residuary Trust to the three trusts. 72. In a letter to Gerald L. Hempt and George F. Hempt dated March 1,2001, Mr. Freedman advised that he had "done a preliminary analysis of the assets held in the trust under Loy's Will to determine how the assets can be divided now into separate trusts to reflect the eventual division after Jean's death according to the terms ofLoy's Will." 20 " ~ 73. In his March 1, 2001 letter, Mr. Freedman further stated, "It was not possible to apportion all of the Hempt Bros. stock to you. It had to be divided among you, your sisters and the Marks' family because it has a relatively high basis as compared to the other assets." 74. As of March 1,2001, Mr. Freedman contemplated that Robert Kalbach would receive all 6,000 shares of the C.A. Hempt Estate stock held in the Loy T. Hempt Residuary Trust. 75. Mr. Freedman wrote again to Gerald L. Hempt on April 11, 2001 in which he "reanalyzed" potential division of the assets held in the Loy T. Hempt Residuary Trust. 76. In his April 11, 2001 letter, Mr. Freedman wrote, "I also considered various other transactions in order to help you and George acquire greater positions in some of your family's businesses. " 77. In his April 11, 2001 letter to Gerald L. Hempt, Mr. Freedman wrote: It is my understanding based on our meeting that you want to increase your ownership in Valley Land Company ("Valley Land") from 11 % (11 shares) to 51 % ( 51 shares) and in C .A. Hempt from 12.5% (3,000 shares) to 37.5% (9,000 shares). This means you need to acquire an additional 40 shares of Valley Land and an additional 6,000 shares of C.A. Hempt. At the same time, you and George would like to ensure that Robert Kalbach not receive any additional shares of Hempt Brothers., Inc. ("Hempt Bros."). George wants to receive as many additional shares of Hempt Bros. as possible. 21 #- ~ 78. In his April 11, 2001 letter to Gerald L. Hempt, Mr. Freedman stated, "Therefore, it is impossible to get all of the Valley Land, Hempt Bros. and C.A. Hempt stock into the right hands as the assets are now." 79. In his April 11, 2001 letter to Gerald L. Hempt, Mr. Freedman identified six potential alternatives for division of the Loy T. Hempt Residuary Trust assets. 80. In his April 11, 2001 letter to Gerald L. Hempt, Mr. Freedman identified that a "positive side" of his alternative number 1 was that Robert Kalbach would not receive shares of Hempt Brothers. 81. With respect to alternative number 2 of Mr. Freedman's letter to Gerald L. Hempt dated April 11, 2001, Mr. Freedman described the outcome as, "[W]e accomplished your goals of gaining 51 % of V alley Land, getting George a significant amount of Hempt Bros. stock and not giving Robert Kalbach any additional shares of Hempt Bros." 82. In all of the alternatives presented by Mr. Freedman to Gerald L. Hempt on April 11,2001, Robert Kalbach would receive shares of Valley Land or C.A. Hempt Estate or both. 83. In a letter dated May 15,2001, Mr. Freedman wrote to George F. Hempt and Gerald L. Hempt proposing another division of the assets of the Loy T. Hempt Residuary Trust into three separate trusts. 22 . .. 84. In his May 15, 2001 letter to George F. Hempt and Gerald L. Hempt, Mr. Freedman stated, "In dividing the assets, my two main goals were to have you receive equally the maximum number of Hempt Bros. shares as possible and not to have any Hempt Bros. shares go to Robert Kalbach." 85. In his May 15, 2001 letter to GeraldL. Hempt and George F. Hempt, Mr. Freedman further stated, "It is not possible to get a larger amount ofHempt Bros. into your hands through a simple division of the Trust because of the different ratios between basis and fair market value of each asset." 86. The May 15, 2001 letter to George F. Hempt and Gerald L. Hempt from Mr. Freedman enclosed a spreadsheet labeled on top "Maximum Shares of Hempt Bros. to George & Gerry Equally." 87. The spreadsheet attached to the May 15, 200 I letter to George F. Hempt and Gerald L. Hempt from Mr. Freedman proposed that Robert Kalbach would receive twenty (20) shares of Valley Land Co. and one thousand three hundred (1,300) shares ofC.A. Hempt Estate. 88. In a separate letter dated May 15,2001 addressed only to Gerald L. Hempt, Mr. Freedman "did a revision ofa basic division of the trust with the goals of you and George receiving equally the maximum number of shares of Hempt Bros. and Robert Kalbach not receiving any shares of Hempt Bros." 23 . I 89. In his revision set forth in the May 15, 2001 letter addressed only to Gerald L. Hempt, Robert Kalbach received six (6) shares of Valley Land stock and one hundred (100) shares ofC.A. Hempt stock. 90. In a letter dated April 23, 2002 to Gerald 1. Hempt, Mr. Freedman provided to Mr. Hempt a document to divide the Loy T. Hempt Trust into separate trusts. 91. In his April 23, 2002 proposed distribution, Mr. Freedman utilized, for the first time, a value of Hempt Brothers in accordance with the buy/sell agreement. In this proposed division, Robert Kalbach did not receive any shares of Hempt Brothers, Valley Land or C.A. Hempt Estate. 92. In a letter to Gerald 1. Hempt dated July 12,2002, Mr. Freedman sent to Gerald Hempt a new document to supersede the document provided on April 23, 2002 because Mr. Freedman had mistakenly omitted the basis of Valley Land in the prior document. 93. In the July 12, 2002 letter to Gerald L. Hempt, Mr. Freedman wrote, "As a result the division is changed slightly, as shown on the enclosed. Kalbach continues to receive no family businesses." 24 p ... . . 94. As a result of the final division of the Loy T. Hempt Residuary Trust performed by Gerald Hempt as Trustee, Robert Kalbach received no interest in Hempt Brothers, Valley Land or C.A. Hempt Estate. 95. In his May 15, 2001 letter to George F. Hempt and Gerald L. Hempt, Mr. Freedman proposed a distribution of the stock in the closely-held family businesses owned by the Loy T. Hempt Residuary Trust as follows: Asset HemDt Trust Mark Trust Kalbach Trust Hempt Bros. Stock 1 , 100 1,023 0 Valley Land Stock 40 29 20 C.A. Hempt Estate 2,500 2,200 1,300 Stock 96. In the fmal purported split and distribution of assets owned by the Loy T. Hempt Residuary Trust by the purported Trustee on April 25, 2002, the distribution of the closely-held family business stock was as follows: Asset Hempt Trust Mark Trust Kalbach Trust Hempt Bros. Stock 1,328 795 0 Valley Land Stock 70 19 0 C.A. Hempt Estate 1,235 4,765 0 Stock 25 ,., . Ii , 97. In determining the value of the shares ofHempt Brothers stock allocated to the issue of Max Hempt and to the issue of Dorothy Mark, Gerald L. Hempt used the book value of the Hempt Brothers stock purportedly justified by a buy-sell agreement dated October 19, 1964. 98. Gerald Hempt allocated no stock of Hempt Brothers, C.A. Hempt Estate and Valley Land Co. to Robert Kalbach because of his belief that Robert H. Kalbach has been "hostile" to the family members running those businesses, and such hostility bodes ill for the future smooth management of those family companies should Robert H. Kalbach become a stockholder. v. PRIMARY LEGAL ISSUES3 1. Did the Trustees of the Loy T. Hempt Residuary Trust breach their fiduciary obligations to the remainder beneficiaries and abuse their discretion by making distributions to the Jean Hempt Estate when the Trustees knew at all times that Jean Hempt had assets well in excess of those needed for her to live in her customary manner? 2. Did the current Trustee of the Loy T. Hempt Residuary Trust, who is also a remainder beneficiary of the Trust as well as a beneficiary of the Jean Hempt Estate, breach his fiduciary obligations to a remainder beneficiary and abuse his discretion by making distributions 3 The Kalbach Objectors have listed herein the primary legal issues in these proceedings. See also the issues set forth in the Objections to Accounting. 26 III tI ' # lit to the Jean Hempt Estate when the result of the distributions is to his personal benefit and at the expense of another remainder beneficiary of the Trust? 3. Did the Trustee of the Loy T. Hempt Residuary Trust breach his fiduciary obligations to the remainder beneficiaries and abuse his discretion by dividing the Trust into three separate trusts and then allocating the assets among those three trusts in the manner described in the Accounting? 4. May the Trustee, who is also a remainder beneficiary of the Trust, utilize 20 Pa. C.S.A. ~7191(a) to divide the trust into separate trusts, and then allocate specific Trust assets he wishes to receive to himself, thereby deliberately depriving those specific Trust assets from another remainder beneficiary? 5. May 20 Pa. C.S.A. ~7191(a) be utilized to distribute assets into divided trusts when those assets are composed primarily of interests in closely-held businesses whose values are disputed, are not readily determinable, and which require complex, subjective and disputed valuation methodologies? 6. Should the Trustee of the Loy T. Hempt Residuary Trust be removed when the Trustee has multiple conflicts of interest, was appointed without notice, has an antagonistic relationship with a remainder beneficiary, and has demonstrated a pattern of conduct for his 27 Ii'- .". t I .. " personal benefit that violates his fiduciary obligations to remainder beneficiaries and constitutes an abuse of discretion? METTE, EVANS & WOODSIDE By: ~1-~ Daniel L. Sullivan, Esquire Sup. Ct.J.D. 34548 Howell C. Mette, Esquire Sup. Ct.J.D. 7217 Vicky Ann Trimmer, Esquire Sup. Ct. J.D. 49679 3401 North Front Street P.O. Box 5950 Harrisburg, P A 1711 0-0950 (717) 232-5000 Attorneys for Kalbach Objectors DATED: d \ .-\1 lY~ 28 388963vl