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',,, .. 'i;'I'}> .' "', .',,' !I' ("'I,:" , " ;i' ("",'" :") ".1; ,d ,I; ','," "'. .' " , 'it .' "'-:"'.1.' :",:"jJ " .1':-' , '.~I J ;'1. . '. ". 'i' i;' ./1','('\ .,,,1 t. .,I\,!l .,~" ," '." I ~ ',~ ' " I"" ..... i. .' . . ,'., .... ". :'" .1. :l1-cr4-Cfo IRREVOCABLE TRUST AGREEMENT THIS AGREEMENT OF TRUST, irrevocably made this~day of ':S" 101 "' ... , 1977, by and between RALPH W. GOBRECHT, of Mount Pleasant Township, Adams County, Pennsylvania, party of the first part, hereinafter referred to as "SF'l'TLOR"I AND DAUPHIN DEPOSIT BANK AND TRUST COMPANY, of Harrisburg, Dauphin County, Pennsylvania, party of the second part, hereinafter re- ferred to as "TRUSTEE", WITNESSETH: WHEREAS, the Settlor is the owner of certain assets referred to on the Schedule "A" attached hereto and made a part of this Agreement; and WHEREAS, the Settlor, for his own convenience and protection, desires to have the aforesaid assets, together with such other as- sets as may be turned over to the Trustee in accordance with the terms hereinafter set forth, invested and managed by the Trustee for uses and purposes described in this trust, and WHEREAS, the Trustee has evidenced its consent to accept the trust, subject to the terms and conditions hereinafter set forth I and WHEREAS I the parties hereto are desirous of setting forth the terms and conditions under which the property is to be held in trust and the uses and purposes to which the same shall be applied by the Trustee. NOW, THEREFORE, in consideration of these premises and of the mutual covenants herein contained, the parties hereto agree as follows: /1'439~"~ . . .. " ~ ' , .' 1. The Settlor does hereby assign, transfer and convey unto the Trustee the property referred to on Schedule A, which property shall be held, IN TRUST, by the Trustee and administered in accordance with the terms and conditions of this Agreement. 2. From time to time the Settlor, the Settlor's estate, or any other person, firm or corporation may deliver to the Trustee other real or personal property to be administered as a part of the wi thin trust, and the Trustee agrees to accept such addi tional property as part of the total trust administered hereunder. Trustee shall invest, reinvest and keep invested the principal of the Trust estate and collect and receive the income therefrom and distribute the net income to Settlor, or any other party for his benefit, for and during the term of his natural Ufe. 3. Trustee is authorized to disburse any part or all of the principal of this Trust at any time or from time to time when in its discretion it shall be expedient for the comfort, maintenance and support of the Settlor, and Settlor's wife, ELIZABETH A. GOBRECHT. 4. Trustee is authorized to disburse the income or the prin- cipal of this Trust as hereinbefore authorized, either directly to the Settlor, or to any other party for his benefit or for his wife's benefit as selected by Trustee to be the recipient thereof without the intervention of a guardian, and the receipt of the party so selected by the Trustee shall be a sufficient acquittance. 5. Upon the death of the Settlor, Settlor disposes of the said assets in this trust, together with any assets received from any other source, including Settlor's estate, as follows: A. If Settlor's wife, ELIZABETH A. GOBRECHT, survives him, Settlor gives to the DAUPHIN DEPOSIT BANK AND TRUST COMPANY, of Harrisburg, Pennsylvania, INTRUSTt to be herein- after referred to as Trust A an amount equal to fifty (50%) per cent of Settlor's adjusted gross estate as finally deter- 2 e, t' ,. . . , " mined for Federal Estate Tax purposes I less the aggregate amount of marital deductions, if any, allowable for such tax purposes by reason of property or interest in property includable in Settlor's adjusted gross estate as aforesaid, which passes to or accrues or which may pass or accrue to the said ELIZABETH A. GOBRECHT, directly or indirectly under any provision of Settlor's will, by operation of law, through insurance, under any trust created by Settlor during his life, or otherwise than by the terms of this Trust. Settlor shall assign, convey and distribute to the said Trustee, cash, securities and other property, including real estate, and any interest therein which may constitute such gift. The cash, securities, real estate and other property so distributed shall be selected in such a manner as to have an aggregate fair market value fairly represen.. tative of the appreciation or depreciation in the value to the date or dates of each distribution of all property then available for distribution. Any property included in Set- tlor's estate at the time of his death and assigned or con- veyed in kind to satisfy said gift, shall be valued for that purpose at the value thereof as finally determined for Federal Estate Tax purposes, and any other property so as- signed or conveyed shall be valued for that purpose at its cost. No asset or proceeds of any asset shall be included in the Trust as to which a marital deduction is not allow- able if not included. Trustee shall hold the said trust and invest and re- invest the same and pay the income therefrom to the said ELIZABETH A. GOBRECHT. If at any time, eJr from time to time, ahe desires to withdraw from the said trust any part or all of the assets thereof, she shall notify Trustee, in writing I of the amount she desires to withdraw, and the 3 . . ,,' o' ... .'. date when she desires the said withdrawal to become effec- tive. Trustee shall pay the amount so indicated in the said written notice to her free and clear of this Trust, in cash, unless, because of the insufficiency of time, Trustee is unable to liquidate sufficient assets, in which case Trustee shall have the authority to make dis- tribution partly or entirely in kind, the assets distri- buted to be valued as of the date of distribution. If at any time or from time to time Trustee shall deem it advisable, even though Trustee has not received a demand from the said ELJ.ZABETH A. GOBHECHT, Trustee is authorized to expend any part or all of the income, or principal of Trust A for the comfort, maintenance and sup- port, and to meet any emergencies pertaining to her. In making payment of either principal or income, Trustee is authorized to distribute the same to any party for said wife's benefit without the intervention of a guardian, and the receipt of such party selected by the Trustee to be the recipient thereof shall be a sufficient acquittance. Settlor further authorizes and empowers his said wife, upon her death, to appoint by her last will and testament that the balance of the corpus of this Trust and any accumulated income, to such one or more parties as she may determine, including herself, her creditors, or her estate, in fee or lesser estate, in trust, or otherwise. If Settlor's said wife shall fail to exer- dse this power of appointment in whole or in part, then upon her death any part of the corpus of this trust not disposed of by ht,r will shall become a part of the rel3i- duary trust hereinafter created and designated Trust B, to be held, invested and distributed under the terms of said Trust. 4 . . u, .' , " ," If the said ELIZABETH A. GOBRECHT shall not survive Settlor, all of the assets of the Trust which would have been a part of Trust A under the terms hereof shall be and become part of Trust B, as hereinafter defined; provided however, that if Settlor and his said wife shall die under circumstances which make it impossible to determine which of the two shall have survived the other, it shall be con- clusiv~ly presumed that Settlor's death occurred first. 6. Settlor directs Trustee to pay from the remainder of the trust after creation of Trust A, all estate, inheritance, sue cession or other similar taxes, irrespective of by what govern- mental authority imposed upon or with respect to any property, real or personal, tangible and intangible, which is required to be included in Settlor's estate for such tax purposes, whether or not such property passes through the hands of Settlor's Execu- tor or Trustee, and no beneficiary shall be charged with any por- tion of such taxes; provided, that any trust or insurance pro- ceeds included in Settlor's estate for Federal Estate Tax pur- poses may at the Trustee's discretion be required to contribute that portion of the tax imposed by any taxing authority by reason of such inolusion, unless such inclusion would violate the terms of the next sentence of this paragraph. Settlor expressly di- rects that any part of his estate, in trust or otherwise, passing to his wife in any manner, shall in its entirety be exonerated from the contribution to the payment or satisfaction of any such taxes. 7. The entire balance of the assets in this Irrevocable Trustt inclUding assets received from Settlor's estate or else- where, not hereinbefore disposed of, including if Settlor's wife predeceases himn, all the assets which would have become part of Trust A if nhe had survived him, Settlor hereby gives to DAUPIlIN DEPOSIT BANK AND TRUST COMPANY, to be hereinafter referred to as 5 . . t. ~ " " " Trust B, to invest, reinvest and to collect and rece.i.ve income therefrom, and after deducting all expenses incident to the said Trust, to add the net income to princi.pal. Settlor I s primary concern for the disposition of the said Trust fund is the wel- fare of his wife, ELIZABETh A. GOBRECHT. In executing the pro- visions pertaining to the disbursement of said Trust B, as here- inafter stated, Trustee shall be guided by this thought. Subject tD the said thought, Trustee is author.ized, at any time or from time to time when in its sole discretion and uncontrolled discre- tion it deems it advisable to pay to or on behalf of Settlor's wife, any part or all of Trust B ~hich Trustee deems necessary for the comfort, maintenance and support and to meet any emer- gency pertaining to her. Trustefl is directed in making a deter- mination as to whether principal from the said Trust shall be disbursed to or for the benefit of Settlor's wife, to take into consideration any other financial resources available to her for these said purposes. Trustee may make distribution of said Trust fund as hereinbefore authorized either directly to the said wife, or to any other party for her benefit, and the receipt of the party so ~e1ected to be the recipient thereof shall be a sufficient acquittance. A. Upon the death of Settlor's wife, or upon Settlor's death, if she shall predecease Settlor, Settlor directs Trustee to divide the balance of the income and principal of this Trust into equal shares for Settlor's children or issue of Settlor's children not then living, per stirpes, and shall hold the same in trust for the following uses and purposes I 1. Trustee shall pay the net income therefrom unto Settlor's children for and during the term of their natural life. 2. Trustee is authorized to expend from the 6 . . , '.1 ".' ," .... principal of their respective share so much thereof as Trustee deems necessary or advisable for the main- tenance, support, education and any other emergencies that may befall Settlor's children or their issue. 3. Upon the death of Settlor's children, the share of such deceased child then remaining shall be held in further trust for the issue of the deceased child, and Trustee shall pay the net income therefrom unto said issuo, and to further authorize to expend so much of the principal as Trustoe deems necessary or advisable for the maintenance, support, education and/or other emergencies that may befall said issue until said issue shall attain the age of twenty-one (21) years, at which time the share of said issue shall be distributed to him or her absolutely. 8. Trustee is authorized and empowered to register any securities held for Settlor or any beneficiary under the terms of this Trust in the name of its nominee. 9. Settlor agrees that Trustee shall be entitled to its usual customary fees for the management of this Trust during its existence and to its usual and customary fees at the te~nination hereof. IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be duly executed the day and year first above written. Witness: ~-:::':>" ;I, 'Z ~"'J_jE/:'~~.c/f{tl)1t It! t,,,lrcilrsEAL) - (Ral~. Gobrecht) Attest: DAUPHIN DEPOSIT BANK AND TRUST COMPANY .~~-::-:;.., . ( .---\-:-~'I~~-.. J By(,..c......"...~ ..."",_ ,- ~.. /1/, "-1/ A~J. Secret ji/ ,l 'Y I . . . Cash 3,000. 5,000. 2,000. '25 She. ...20 She. 100 She. 300 She. 200 She. 100 She. '10 She. 200 She. 500 She. .10 She. .50 She. 300 She. 100 She. 100 She. 100 She. OWts. . .", ", . 18 ... SCHEDULE A Westmoreland Co., Munio. Auth. 2.80%. 7-1-78 Sperry Rand ~urp.6% 12-15-2000 . Amerioan Motor Inns, Ino. 5-1r% 2-1-91 Penna. Power & Light, 13.00 Pfd. IBM Georgia Power Co. 2.52 Pfd. FedelooI', Ino. Duquesne Light Co. 2.10 Pfd. Penna. Power & Light Weet Penn Power Co. 7.00 Pfd. United Teotonio Industries, Ino. Deoatur Inoome Fund, Ino. Jersey Central Power & Light 00. 11% Pfd. Publio Service Elec. & Gas Co. 12.25% Pfd. Tesoro Petroleum Oorp. 2.16 Pfd. Medusa Corp. Martin Marietta Oorp. Talley Industries, Inc. . ,. I:"~ United Teot9nio Ind. Ino. - Exp. 9-30-71 " . .. ,.. .' , /: ,10,000.00