HomeMy WebLinkAbout21-2004-87 Orphan's
IN RE: ESTATE OF
JOSEPH D. BRENNER, SR.,
JOSEPH D. BRENNER, JR. AND
MARGARET B. BUSHEY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
V.
MANUFACTURERS AND TRADERS
TRUST COMPANY a New York
Corporation, DAVID C. GORITY, an
Individual and CURT R. STAUFFER, an:
Individual
No. 21-2004-087
IN RE: JOSEPH D. AND JANE W.
BRENNER TRUST
No. 21-2003-879
IN RE: JANE W. BRENNER TRUST
UWO"B"
No. 21-2003-881
IN RE: JANE W. BRENNER TRUST
UWO"C"
No. 21-2003-881
IN RE: NANCY B. BLAKELY TRUST
No. 21-2003-883
IN RE: CROSS-EXCEPTIONS TO AUDITOR'S REPORT
OPINION AND INTERIM ORDER OF COURT
Bayley, J., May 24, 2005:--
Joseph D. Brenner, Sr. and his wife, Jane W. Brenner, executed an intervivos
trust for the benefit of their four children, and upon the deaths of those children, to their
grandchildren. Margaret B. Bushey and Joseph D. Brenner, Jr., two Brenner children,
and the Manufacturers and Traders Trust Company (M& T Bank), are co-trustees of
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this "Grandchildren's Trust" (Joseph D. and Jane W. Brenner Trust - No. 21-2003-
879).
Jane W. Brenner executed three intervivos trusts for the benefit of Brenner, Sr., and
the four Brenner children. Brenner, Sr. and M&T Bank are the co-trustees of these
"Children's Trusts" (Jane W. Brenner Trust UWO "B" - No 21-2003-881; Jane W.
Brenner Trust UWO "c" - No. 21-2003-881; and Nancy B. Blakely Trust - No. 21-2003-
883). Jane W. Brenner is now deceased. The institutional co-trustee of all of the trusts
was originally the Farmers Trust Company, which became Keystone Financial N.A.,
which became M&T Bank. David C. Gority, an employee of M&T Bank, is primarily
responsible for working with Brenner, Sr., Brenner, Jr., and Bushey with respect to all
of the trusts. Curt R. Stauffer of M& T Bank assists Gority.
At the inception of the trusts, the sole corpus was the stock of AMP, Inc.
Brenner, Sr., now 87 years old, is a former chief executive officer of AMP, Inc. He has
served as a director of the Farmers Trust Company and currently serves as the director
of Frog, Switch and Company, Inc., a local industry. The AMP, Inc. stock converted to
Tyco International, LTD. All of the remaining shares of Tyco stock in the trusts were
sold on June 12, 2002. It is that sale which gave rise to the claims of the individual
trustees for a surcharge against M& T Bank, Gority and Stauffer for an alleged breach
of fiduciary duty in the administration of the trusts. The claims were assigned to an
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auditor who conducted hearings and filed a report and recommendation.1 The auditor
concluded that M& T Bank, Gority and Stauffer did not breach a fiduciary duty in
administering the trusts. No surcharge was recommended. The auditor recommended
that M& T Bank not recover the cost of its defense. The individual trustees and M& T
Bank filed exceptions to the auditor's report.
The Judicial Code at 42 Pa. C. S. Section 102 provides for the appointment, inter
alia, of auditors and masters. The Orphans' Court Rules of the Pennsylvania Supreme
Court provide:
RULE 7.1 EXCEPTIONS
Exceptions shall be filed at such place and time, shall be in such
form, copies thereof served and disposition made thereof as local rules
shall prescribe.
Cumberland County Orphans' Court Rule 8.7-2, titled OBJECTIONS, provides:
Objection to the auditor's report shall be filed with the Clerk within
twenty days after receipt of the notice of filing of said report. Objections
shall be specific as to the basis of the Objection whether as to the
findings of fact or conclusions of law or both.
RULE 8.7 CONFIRMATION OF REPORT
(a) The report of an auditor shall be confirmed in such manner as
local rules shall prescribe.
1 The claims were originally filed in the Civil Division. A preliminary objection to the
Brenners' complaint was granted. The claims were then transferred to the Orphans'
Court Division. Brenner v. Manufacturers and Traders Trust Company, 53
Cumberland L.J. 49 (2004).
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The scope of our review of the exceptions to the auditor's report is set forth in In
re Sweeney, 695 A.2d 426 (Pa. Super. 1997). This court has the authority to accept or
reject the report and recommendations in whole or in part, to remand to supplement the
record or for consideration of issues not fully considered, to hold hearings to
supplement the findings, or to allow oral argument and submission of briefs, all before
entering a final order. In the present case, we heard oral argument on briefs on March
23, 2005, and have not taken additional evidence. The individual Trustees have
briefed four exceptions to the auditor's report. M& T Bank has briefed one exception.
EXCEPTIONS OF THE INDIVIDUAL TRUSTEES
I. Brenner Sr.'s Diminished Capacity is a Fundamental Issue,
and the Court Should Hear Evidence on this Issue Itself.
Among the findings made by the auditor are:
Brenner, Sr., is best described as having a hands on philosophy
with respect to all of the Trusts, notwithstanding the fact that he is not a
Co-Trustee to the Grandchildren's Trusts.
Brenner, Jr., and Bushey deferred to Brenner, Sr., with respect to
all dealings with M&T Bank and all decisions made with respect to the
retention or disposition of the Tyco stock in these Trusts.
In February of 2000, the Grandchildren's Trust was. . . partially
diversified by the sale of a portion of the Tyco stock contained therein.
This was done to increase the income flow to the beneficiaries of this
Trust. The proceeds were utilized to purchase tax free municipal bond
type investment.
On August 20, 2000, Brenner, Sr., reaffirmed, in writing, his desire
that all shares of Tyco stock be retained in the Trusts.
M& T, as well as its predecessors, repeatedly counseled and
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advised Brenner, Sr., along with Brenner, Jr., and Bushey, as to its
concerns with respect to holding Tyco stock only in the Trusts.
M& T, through Gority and Stauffer, on numerous occasions, urged
Brenner, Sr., along with Brenner, Jr., and Bushey to diversify its holdings
in the Trusts.
The value of Tyco stock fell from about $55.00 per share in the
later part of 2001 to $10.00 per share on or about June 2, 2002.
In June of 2002 M&T Bank recommended that Tyco stock be off-
listed and expressed concerns as to possible bankruptcy of Tyco.
From January 2002 to June 2002, Gority and Stauffer repeatedly
advised Brenner, Sr., along with Brenner, Jr., and Bushey, to diversify the
holdings of the Trusts.
M& T's concerns relative to the high concentration of Tyco stock in
the Trusts heightened during the early part of June 2002. Concerns
arose as a result of accounting irregularities, the arrest of Tyco's Chief
Executive Officer, Dennis Kozlowski, amid charges to tax fraud and other
allegations of wrong-doing.
On June 7,2002 Stauffer contacted Brenner, Sr., Brenner, Jr., and
Bushey to specifically inform them of M& T's decision to no longer hold
Tyco stock in any of its model portfolios.
On June 7, 2002 Tyco stock closed at approximately $10.00 per
share.
On Monday, June 10, 2002, Stauffer spoke with Brenner, Sr. and
scheduled a meeting for Wednesday, June 12, 2002, to discuss options
and recommendations concerning the Tyco stock in the Trusts.
Stauffer was advised by Brenner, Sr., that only he would be
attending the June 12, 2002 meeting and that only he would be
representing the interests of the Trusts.
The June 12, 2002 meeting was attended by Gority, Stauffer and
Brenner, Sr. John Klobusicky, Senior Investment Officer in Pennsylvania
for M& T, participated by speakerphone.
Gority and Stauffer offered an explanation as to concerns and
advised as to options. The Bank recommended that one-third (1/3) of the
Tyco shares held in the Trusts should be sold immediately, with a "stop
loss [sic]" order to be placed at $9.00 per share on all remaining shares.
Brenner, Sr., at the conclusion of the June 12, 2002 meeting,
signed two (2) written authorizations. One authorization directed the
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immediate sale of one-third (1/3) of the Tyco shares in the Trusts in which
he was the Co-Trustee (the Children's Trusts). The second signed written
authorization authorized the use of a stop loss [sic] order on the balance
of the shares at $9.00 per share. Again pertaining to those Trusts in
which he was the Co-Trustee.
Brenner, Sr., fully understood and voluntarily signed both written
authorizations.
Brenner, Sr.'s written authorizations constituted his consent. Given
the totality of the circumstances, the consent was informed consent.
Gority and Stauffer properly and professionally explained the
circumstances and their concerns with respect to the Tyco stock and,
further, advised as to their recommendations at the June 12, 2002
meeting. This meeting lasted approximately one (1) hour.
Immediately following the termination of the June 12, 2002 meeting
with Brenner, Sr., Gority contracted and received approval via telephone
from Brenner, Jr., and Bushey to sell one-third (1/3) of the stock in the
Grandchildren's Trust and to place the stop loss [sic] order.
Brenner, Sr., at no time immediately subsequent to the June 12,
2002 meeting and the placement of his signature on the two (2)
authorizations, advised Gority, Stauffer or any other M& T employee or
official that he did not understand or appreciate the explanations given
nor the actions that he authorized. Brenner, Sr., did not suggest to
anyone during or immediately following the June 12, 2002 meeting that he
needed additional time to consider M& T's recommendations as made by
Stauffer and Gority or, further, did he request time to speak with Brenner,
Jr., Bushey or his accountant.
Objectors have not established, through Dr. Joseph F. Brazel, or
otherwise, that Brenner, Sr., had reduced mental capacity on or before
June 12, 2002, such that Brenner, Sr. did not appreciate and understand
the advice and recommendations provided by M& T.
Dr. Joseph S. Brazel's diagnosis that Brenner, Sr. suffered from
senile dementia, Alzheimer's type, prior to June 2002 was based upon
observations only. No clinical tests, including the Wechsler test or any
other evaluations were given.
Dr. Brazel did not communicate his diagnosis to Brenner, Jr.,
Bushey or any other member of the Brenner family. Dr. Brazel did not
recommend that Brenner, Sr. stop driving his motor vehicle. Dr. Brazel
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did discourage Brenner, Sr. from driving his motor vehicle on the
interstates.
Brenner, Sr., on or before June 12, 2002 was capable of making
decisions regarding the disposition and sale of the Tyco stock in the
Trusts. Neither Brenner, Jr., Bushey, nor Dr. Joseph F. Brazel, Brenner,
Sr.'s personal physician, communicated to Gority, Stauffer, or any other
employee or representative of M& T, or it predecessors, their concerns
andlor diagnosis that Brenner, Sr. was suffering from a reduced or
diminished mental capacity on or before June 12, 2002.
Gority testified that he never had a reason to doubt Brenner, Sr.'s
capacity. Furthermore, Gority testified that he would never have
participated in nor would he have allowed Brenner, Sr., to make decisions
or sign documents if he had any question as to his lack of sufficient
mental capacity.
The auditor concluded:
[t]hat Brenner, Sr., did, in fact, possess sufficient mental capacity
to know, appreciate and understand the advice, opinions and
recommendations that were given to him on June 12, 2002 by Gority,
Stauffer and Klobusicky. Furthermore, it is clear that Brenner, Sr.,
understood and voluntarily executed the authorizations resulting in the
immediate sale of one-third (1/3) of the Tyco stock holdings, along with
the stop-loss order involving the remaining shares, all with respect to the
Children's Trusts, of which he was Co-Trustee. . . .
The most persuasive evidence as to the mental competency of
Brenner, Sr., was his own testimony. Clearly, Brenner, Sr., in his own
words, was not physically capable at age 87 of doing all the things that he
previously did and enjoyed. This is a natural part of the aging process
and is perfectly understandable. However, Brenner, Sr., by his own
testimony, stated that he was perfectly capable of handling his own
financial affairs. Both under direct and cross examination, Brenner, Sr.,
exhibited a very clear ability to comprehend questions asked and to
respond accordingly. As to cross examination, Brenner, Sr., more than
held his own.
It is important to note that Brenner, Sr.'s alleged incapacity was not
communicated to M& T Bank through either Gority or Stauffer or any other
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individual. No communication as made by Brenner, Sr., Brenner, Jr.,
Bushey, or Dr. Joseph F. Brazel, Brenner, Sr.'s doctor. Shawnee Smith,
an M&T Bank employee had interacted with Brenner, Sr., since 1987.
Although Shawnee Smith noted changes, those changes were primarily
physical, being attributed to the normal aging process. Throughout their
interactions Brenner, Sr., exhibited a high degree of professionalism and
knowledge, particularly with respect to his bank dealings.
The individual trustees alleged that M& T Bank and its employees breached a
fiduciary duty by capitalizing on Brenner, Sr.'s reduced physical and mental condition in
order to sell all Tyco stock held by the trusts.2 After examining the record we are
satisfied that the finding of the auditor that Brenner, Sr. was capable of making
decisions and did make decisions regarding the sale of the Tyco stock is supported by
the evidence, and we accept it. There is no basis for this court to separately litigate the
issue of Brenner, Sr.'s capacity in this regard.
II. Based on the Undisputed Facts, M& T's Recommendation to
Enter a $9.00 Stop-loss Order on June 12, 2002, Was Negligent
as a Matter of Law. The Auditor Also Did Not Make
Adequate Findings on this Issue.
The individual trustees maintain that M& T Bank and its employees were
negligent as a matter of law for recommending the entry of a $9.00 stop-loss order on
June 12, 2002, which resulted in the Tyco stock being sold. Despite the fact that the
stock price had been declining precipitately, the individual trustees argue that the bank
2 There is no issue here that the recommendation of the Bank to sell the Tyco stock
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did not explain to them how the stop-loss order worked, how the $9.00 trigger price was
set, how it tested the trigger price, or the likelihood of the $9.00 stop-loss order
triggering in the current markee They argue in their brief:
First, M& T should have communicated downside hedging options to
Petitioners as part of the November 2001 presentation, or at least once
Tyco's stock price began declining precipitously in early 2002. Second,
and more importantly, when M& T finally did recommend a downside
hedging mechanism for the first time on June 12, 2002, Stauffer failed to
adequately test the stop-loss trigger price that he recommended to
reasonably ensure it would not trigger based solely on intraday market
volatility.
The individual trustees contacted the Bank on June 13, 2002, and expressed
displeasure that Tyco stock had been sold. Brenner, Sr., told Gority that he did not
understand the stop-loss order, and hung-up on him, which was something he had
never done. Gority wrote a memorandum stating that Brenner said he "did not
understand that we had explained the stop-loss to him and that he thought we will not
sell shares below $9.00 per share." Curt Stauffer testified that he explained the stop-
loss order to Brenner, Sr.: "[t]hat it was outside of a normal one day trading volatility of
the stock. So therefore, just normal market ups and downs would not necessarily
was not within the standard of care required of it as a fiduciary.
3 M& T Bank had repeatedly recommended diversification of the trust assets well before
the Tyco stock was selling at $57 per share in January, 2002. In February, 2002, it was
selling around $35. In May, around $20.
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trigger the stop-loss." The individual trustees argue that this explanation was deficient
because of the failure "to back test the $9.00 trigger price in the existing market and
explain that a trigger price set 15% below current trading price would have triggered on
three of the last seven trading days." On June 12, Tyco opened at $10.90 and closed
at$10.15.4
The primary duty of a trustee is the preservation of the assets of the trust and
the safety of the trust principal. In re Estate of Lychos, 323 Pa. Super. 74(1983). A
trustee is obligated to exercise a standard of care which a person of ordinary prudence
would practice in the case of that person's own estate. See In re Estate of Scharlach,
809 A.2d 376 (Pa. Super. 2002). If a fiduciary has a greater skill than that of a person
of ordinary prudence, then the standard of care must be judged according to the
standard of one having this special skill. Estate of Pew, 655 A.2d 521 (Pa. Super.
1994). We agree with the auditor that M&T Bank, as the corporate fiduciary, owed a
higher standard of care than an individual of ordinary prudence. Given the state of the
market and Tyco stock, the recommendation by the Bank to sell the stock did not fall
4 On June 3, 2002, the high was 18.800 and the low was 15.600. On June 4, the high
was 16.800 and the low was 15.550. On June 5, the high was 17.750 and the low was
16.910. On June 6, the high was 17.300 and the low was 14.400. On June 7, the high
was 12.550 and the low was 9.450. On June 10, the high was 11.750 and the low was
10.300. On June 11, the high was 11.250 and the low was 10.500.
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below the standard of care of a corporate fiduciary.5 The Bank had the approval of the
individual trustees at a stop-loss of $9.00. The Bank was not negligent based on the
complaints of the individual trustees about the execution of that order so as to support
their claim for a surcharge because the stock was sold.
III. The Auditor Did Not Discuss M& T's Failure to Advise
Petitioners that It Could "Reverse" the Disputed Sell
Orders, and Did Not Make Adequate Findings of Fact on
This Issue to Reach a Conclusion of Law.
Under trading regulations, M& T Bank could have reversed the sale of the stock
for three days after June 12, 2002. The Bank did not advise the individual trustees of
that possibility. Nor did the individual trustees request that the Bank reverse the sale.
The individual trustees argue in their brief:
Once M& T was put on notice on the morning of June 13 that its co-
trustees were upset and concerned, and specifically asserted that they
had not understood what they had allegedly authorized the prior day,
M&T was obligated to at least notify Petitioners of their options including
the three-day window for reversing the transactions.
Even if the Bank should have notified the individual trustees that the sale of the
Tyco stock could have been reversed in three days, it does not support their claim that
such a failure warrants a surcharge as there was no breach of a fiduciary duty in having
5 Margaret B. Bushey and Joseph D. Brenner, Jr., the individual trustees of the
Grandchildren's Trust, sold 40% of Tyco stock in that trust in 1999 after discussions
with the co-trustee, M& T Bank.
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the stock sold in the first place. Whether the sale could have been reversed,
seemingly pursuant to an agreement among the trustees, does not turn that sale into a
breach of a fiduciary duty on the part of the Bank.
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IV. The Auditor Failed to Consider or Rule on Petitioners' Claims
Against M& T for Refusing to Transfer the Trust Assets to the
Lawfully Appointed Successor Trustee
The trust instruments allow the individual trustees authority to remove M& T Bank
and to appoint a successor institutional trustee. The individual trustees appointed
Orrstown Bank as a successor trustee, and on September 30, 2003, gave M& T Bank
notice and a demand to transfer assets of all of the trusts. M& T Bank has not
transferred the assets. The individual trustees maintain that the Bank breached a
fiduciary duty in failing to transfer the assets to the Orrstown Bank, and that the trusts
have been damaged as a result. On October 24,2003, M&T Bank filed accounts
seeking confirmation and a proposed distribution to Orrstown Bank to become the
successor trustee.6 Exceptions were filed to each account based on the claims made in
this litigation. The accounts were not confirmed as an auditor was appointed.7 The
6 Joseph D. and Jane W. Brenner Trust, No. 21-03-879, First and Final Account for
period between December 5, 1994 to September 25, 2003; Jane W. Brenner Trust
UWO "B", No. 21-03-881, First and Final Account for period between August 10,1998
to September 25,2003; Jane W. Brenner Trust UWO "C", No. 21-03-881, First and
Final Account for period between August 10, 1998 to September 25, 2003; Nancy B.
Blakely, No. 21-03-883, First and Partial Account for period between May 21, 1985 to
September 25, 2003.
7 M& T Bank attempted to obtain a release from the individual trustees that it felt would
protect it if it transferred the assets before there was a confirmed account and an order
of distribution. The individual trustees would not enter into a release acceptable to the
Bank.
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auditor has recommended no surcharge, and that the accountings filed by the Bank
should be confirmed with distribution directed in accordance with the accounts. The
Bank's refusal to distribute the trust assets prior to such confirmation as provided for in
Pa. O.C. Rule 6.11 (a), does not constitute a breach of fiduciary duty warranting a
surcharge.
EXCEPTION OF M&T BANK
Having successfully defended its account, M& T is entitled to recover
its attorney fees from the Trust.
In Pennsylvania, attorney fees may only be awarded in a particular case if there
exists an express statutory authorization, a clear agreement by the parties, or some
other established exception to the general rule that each party bears its own costs.
Merlino v. Delaware County, 728 A.2d 949 (Pa. 1999). Without discussion, the
auditor made the following Conclusion of Law: "M& T is not entitled to recover the cost
of its defense in these matters." M&T Bank maintains that it is entitled, as a matter of
law, to attorney fees in its successful defense of the claims made against it. There is
an exception to the general rule regarding an award of attorney fees set forth in In re
Coulter's Estate, 379 Pa. 209 (1954), where the Supreme Court stated:
We also conclude that the court below did not err in allowing the
attorney for the accountant (trustee) a fee out of the trust assets in the
sum of $2,000 for his services for and in behalf of Richard Coulter. As
this Court stated in Wormley Estate, 359 Pa. 295, 300: "It is well
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established that whenever there is an unsuccessful attempt by a
beneficiary to surcharge a fiduciary the latter is entitled to an allowance
out of the estate to pay for counsel fees and necessary expenditures in
defending himself against the attack."
The individual co-trustees argue in their briefs that this exception is not
applicable because:
It is undisputed that each of the Petitioners is a beneficiary of one or more
of the trusts. However, Petitioners are also the co-trustees of all of the
trusts at issue, they brought suit against M&T as co-trustees to fulfill
those obligations, not in their capacity as beneficiaries.
Brenner, Sr., is the life beneficiary under the "Children's Trust," with Brenner, Jr.,
Bushey and the two other children being the remaindermen. The children are the life
beneficiaries under the "Grandchildren's Trusts," with the grandchildren being the
remaindermen. In In re Browarsky's Estate, 437 Pa. 282 (1970), Lewis Sheppard and
Dora Foster were the executors and trustees under the will of decedent. The will
provided for devises and bequests to, among others, Sheppard and Foster. A final
decree of distribution was entered to which the residuary beneficiaries filed exceptions
to surcharge the co-executors. The exceptions were dismissed by the Orphans' Court
and affirmed on appeal. Thereafter, the attorneys who served as counsel in opposition
to the attempted surcharge petitioned for allowance of their fees to be paid by the
estate. Because any payment by the estate would be drawn from the residue, the
residuary legatees contested the petition. The Orphans' Court awarded attorney fees.
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The order was affirmed by the Supreme Court of Pennsylvania, which stated:
We begin our consideration with an explanation of why it was
appropriate for the attorneys for the executors to seek payment of their
fees from the estate. The executors were placed in the position to be
sued because of duties they had performed for the estate. That
being the case, it would be unjust to require them personally to bear
the reasonable costs of the defense of suits brought against them
solely by reason of their positions as executors. "It is well
established that whenever there is an unsuccessful attempt by a
beneficiary to surcharge a fiduciary the latter is entitled to an
allowance out of the estate to pay for counsel fees and necessary
expenditures in defending himself against the attack [citing cases]."
Wormley Estate, 359 Pa. 295, 300-01, 59 A. 2d 98, 100 (1948). Accord:
Coulter Estate, 379 Pa. 209, 108 A. 2d 681 (1954). Thus, it is clear that
the estate was obligated to pay the reasonable costs of defending against
the attempted surcharge of the executors by the residuary beneficiaries
... (Emphasis added.)
That reasoning applies in the present case. Quibbling about whether the
Brenners, who are beneficiaries of the trusts, sought a surcharge in their capacity as
co-trustees, is of no significance. M& T Bank, the fiduciary, has successfully defended
their claims for a surcharge. It is entitled to an allowance out of the trust estates to pay
its attorney fees. Rather than return the issue to the auditor we will resolve it in this
court.
For the foregoing reasons, an interim order will be entered. Once the issue
involving attorney fees is resolved a final order will be entered, pursuant to this opinion,
dismissing the exceptions of the individual trustees to the auditor's report, and
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awarding attorney fees.8
INTERIM ORDER OF COURT
AND NOW, this
day of May, 2005, IT IS ORDERED:
The exception of M&T Bank to the Auditor's Report, IS SUSTAINED. M&T Bank
shall file and forward to this judge a petition with a Rule to show cause why its attorney
fees should not be granted. The petition shall detail those fees. If the Rule is
answered and the fees requested are challenged on the basis of reasonableness or
necessity a hearing will be scheduled. Otherwise, the Rule will be made absolute and
an order awarding the attorney fees will be entered.
By the Court,
Edgar B. Bayley, J.
William F. Martson, Jr., Esquire
1600 Pioneer Tower
888 S. W. Fifth Avenue
Portland, Oregon 97204-2009
Mark D. Bradshaw, Esquire
P.O. Box 11670
Harrisburg, PA. 17108-1670
:sal
8 We will not at the same time order the accounts confirmed and distribution even
though the exceptions will be dismissed. Amended, updated accounts and requests for
distribution will thereafter have to be filed.
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