The Florida Probate Rules are amended regularly in two-year cycles. The Florida Supreme Court just published these amendments to the Florida Probate Rules as part of that cycle, effective January 1, 2006.
"Trust, but verify." That's what Ronald Reagan used to say about negotiating with the Soviet Union, but this maxim also applies whenever one person is entrusted with the care of another person's money. This New York Law Journal is but the latest example of that point. A retired partner of one of the largest and most prestigious law firms in the country, Paul, Weiss, Rifkind, Wharton & Garrison, has been disbarred for stealing more than $500,000 from a family trust for which he was a trustee. Allan L. Blumstein admitted he essentially depleted an account intended to benefit his elderly aunt, who was suffering from dementia and was confined to a nursing home. The former litigator said he took the money to maintain a lavish but unaffordable lifestyle, without which he feared his wife would leave him.
Disputes revolving around whether the trustee of a "discretionary" trust acted appropriately or not often get bogged down because one side or the other fails to grasp the following basic concept: in Florida, discretionary authority does not translate into "I-can-do-whatever-I-want" authority. This Florida Bar Journal article by attorney Peter B. Tiernan does an excellent job of summarizing the current state of the law in Florida on this point.
Former Playboy model Anna Nicole Smith is taking her claims against the estate of J. Howard Marshall II, an oil tycoon who married her in 1994 when he was 89 and she was 26, all the way to the U.S. Supreme Court! The Associated Press reported here that the U.S. Supreme Court has granted cert in Marshall v. Marshall, 04-1544, to answer the following question: when may federal courts hear claims that are also involved in state probate proceedings? When the Ninth Circuit earlier ruled here on the so-called "probate exception" to federal jurisdiction, it held as follows:
We hold that all federal courts, including bankruptcy courts, are bound by the probate exception to federal court jurisdiction and that we are required to refrain from deciding state law probate matters, no matter how the issue is framed by the parties. We vacate the district court's final judgment and remand with instructions.
As I previously posted here, the stripper-turned-reality-TV-star stands to win as much as $474 million that a bankruptcy judge initially said she was owed. The self-described "blonde bombshell" claims that her husband promised her millions but that his scheming son cut her out of the estate.
As the Chicago Sun-Times reported here, this case promises to liven things up at the Supreme Court:
The case promises to be the sexiest of the nine-month [Supreme Court] term which begins next week.
"She's very excited. She will be attending arguments, there's no question about that," Smith's lawyer, Howard K. Stern, said from Vermont where the television reality star is filming a movie.
Interim Healthcare of Northwest Florida, Inc. v. Estate of Ries, 2005 WL 2219224 (Fla. 4th DCA September 14, 2005) (Trial Court Affirmed)
Two public-policy priorities play themselves out every time a creditor seeks to satisfy its claim against a probate estate: (1) on the one hand, there is the public policy favoring expeditious and low-cost completion of the probate administration process; (2) on the other hand, a creditor's constitutionally protected due process rights must respected. As this case makes clear, procedural safety nets available to litigants in general civil litigation (think due process) do not always apply in the probate context. In general civil litigation Rule 1.540 of the Florida Rules of Civil Procedure provides for the "vacatur" of mistaken orders. As the creditor in this case learned, Rule 1.540 runs head on against the public policy favoring the expeditious and low-cost completion of probate proceedings. As such, as the Fourth District Court of Appeal makes clear in Footnote 1 to this opinion, Rule 1.540 simply does not apply in the probate context.
FN1. The Florida Probate Rules do not contain a provision for vacatur of orders--and this includes those striking claims as untimely--made final by the lapse of the time for appeal. The Rules of Civil Procedure no longer apply in probate except as specified in the probate rules. See Fla. Prob. R. 5.010. At one time a statute applied the civil rules to adversary proceedings in probate, but that statute was repealed in 2002. See Ch.2001-226, § 8, Laws of Fla. Thus, even though rule 1.540 might logically seem to support an attempt to vacate an earlier probate order made final by the lapse of the time for appeal, in this case that rule has no application. See In re Estate of Clibbon, 735 So.2d 487 (Fla. 4th DCA 1998).
The LA Times recently reported here on the bitter and lengthy on-going litigation involving a $400 million testamentary trust between the decedent's third ex-wife (who also happens to be the guardian of the 13 year old boy who is the principal beneficiary of the trust) and the trustees. Battles over how an estate is administered, be it a probate estate being administered by a personal representative or a trust estate being administered by one or more trustees, are far and away the leading causes of probate litigation. These disputes are foreseeable, and can be mitigated (although not eliminated) with proper planning.
Rasmussen v. Rasmussen, 2005 WL 2138710 (Fla. 2d DCA September 7, 2005) (Trial Court Reversed)
Although this is a divorce case, the issue of when and "if" a gift actually transfers property rights comes up quite often in the probate-litigation context. So this case should be of interest to trusts and estates planners as well as litigators.
Former major league ball player Dennis L. Rasmussen signed the following note, dated June 10, 1999, which bore the signature and stamp of a notary public (but without a jurat or acknowledgment):
I, Dennis Rasmussen, in sound mind and body, wish to have my wife, Jan S. Rasmussen, receive all property, including personall [sic], in the event of death or separation. I hereby give up any right of any joint or individually held monetary [sic] and property due to any of the above circumstances. This agreement will remain in effect until an [sic] mutually agreed upon revision replaces the above. (Emphasis added.)
Not unreasonably, Mrs. Rasmussen tried to hold him to this "gift" after filing for divorce. Mr. Rasmussen apparently had a change of heart and argued he didn't really mean to give her anything. Hillsborough County Judge Manuel A. Lopez didn't buy this argument, and ruled against him. Unfortunately for the soon-to-be "ex" Mrs. Rasmussen, on appeal the Second District Court of Appeal reversed the trial judge, basing its ruling on the following excellent summary of the current state of the law in Florida with respect to when a gift effectively passes title to property:
We have previously outlined the principles used for determining whether there has been a valid gift: It is well settled that to effectively pass title by gift there must be a surrender of dominion over the res, coupled with the intent then and there to pass title. In other words, there must be an immediate vesting of some interest in the donee, complete and irrevocable. If the donor withholds divestiture it is not a legal gift. A delivery which does not confer the present right to reduce the res into possession of the donee is insufficient. . . .Under these principles, the note of June 6, 1999, did not make a valid gift of the husband's property to the wife. According to the terms of the note, the wife's rights would come into existence only "in the event of death or separation." The note thus provided for a conditional, future transfer of the property; it did not give the wife a present right to the property. Since the note was ineffective as a gift of the husband's property to the wife, the trial court erred in treating the assets in question as marital assets subject to equitable distribution.
This is my running list of Florida probate cases for 2006. Like any compilation, the criteria for inclusion is somewhat subjective, so I'm certainly not guaranteeing that I've identified every case that could conceivably be related to probate matters in Florida. However, if you think I've missed an important probate-related case that deserves wider notice, please let me know. As new cases are published, they'll be added to this list.
All of the cases listed below are also cross referenced by topic, so if you ever want to come back to that homestead case you remember seeing, you can simply jump to all of the homestead cases and scroll through those.
1. Tallahassee Memorial Regional Medical Center, Inc. v. Petersen, 2006 WL 88489 (Fla. 1st DCA Jan 17, 2006) (Contested Guardianship Proceedings)
2. Siegel v. Novak, 2006 WL 119545 (Fla. 4th DCA Jan 18, 2006) (Practice & Procedure)
3. Vargas v. Acosta, 2006 WL 120182 (Fla. 3d DCA Jan 18, 2006) (Contested Guardianship Proceedings)
4. McEnderfer v. Keefe, 2006 WL 129320 (Fla. Jan 19, 2006) (Homestead Litigation)
5. Weisfeld-Ladd v. Estate of Ladd, 2006 WL 231481 (Fla. 3d DCA Feb 01, 2006) (Spousal Elective Share Claims)
6. Eccles v. Nelson, 2006 WL 192633 (Fla. 5th DCA Jan 27, 2006) (Practice & Procedure)
7. Faerber v. D.G., 2006 WL 287322 (Fla. 2d DCA Feb 08, 2006) (Creditors' Claims)
8. Engelke v. Estate of Engelke, __ So.2d __ (Fla. 4th DCA February 8, 2006) (Homestead Litigation)
9. Tripp v. Salkovitz, __ So.2d __ (Fla. 2d DCA Feb 08, 2006) (Contested Guardianship Proceedings)
10. In re Estate of Wejanowski, __ So.2d __ (Fla. 2d DCA February 15, 2006) (Compensation Disputes)
11. Roberts v. Sarros, __ So.2d __ (Fla. 2d DCA Feb 15, 2006) (Will and Trust Contests)
12. McMonigle v. McMonigle, __ So.2d __ (Fla. 2d DCA Feb 17, 2006) (Compensation Disputes)
13. Simpson v. Estate of Simpson, __ So.2d __ (Fla. 5th DCA Feb 17, 2006) (Creditors' Claims)
14. Somogyi v. Nevai, __ So.2d __ (Fla. 4th DCA Feb 22, 2006) (Appellate Practice in Probate)
15. Benedetto v. Columbia Park Healthcare Systems, __ So.2d __ (Fla. 5th DCA Mar 10, 2006) (Practice & Procedure)
16. Demayo v. Chames, __ So.2d __ (Fla. 3d DCA Mar 15, 2006) (Homestead Litigation)
17. In re Estate of Faskowitz, __ So.2d __ (Fla. 2d DCA Mar 31, 2006) (Practice & Procedure)
18. McMonigle v. McMonigle, __ So.2d __ (Fla. 2d DCA Mar 29, 2006) (Compensation Disputes)
19. Martinez v. Ipox, __ So.2d __ (Fla. 2d DCA April 07, 2006) (Wrongful Death Claims)
20. Pastor v. Pastor, __ So.2d __ (Fla. 4th DCA April 19, 2006) (Will and Trust Contests)
21. Della Ratta v. Della Ratta, 2006 WL 1235760, 31 Fla. L. Weekly D1325 (Fla. 4th DCA May 10, 2006) (Will and Trust Contests)
22. Brigham v. Brigham, __ So.2d __ (Fla. 3d DCA May 31, 2006) (Compensation Disputes)
23. Vinson v. Johnson, __ So.2d __, 2006 WL 1650609 (Fla. 1st DCA June 16, 2006) (Will and Trust Contests)
24. University of Miami v. Wilson, __ So.2d __, 2006 WL 1687685 (Fla. 3d DCA June 21, 2006) (Wrongful Death Claims)
25. Owens v. Estate of Davis, ex rel. Holzauser, __ So.2d __, 2006 WL 1716786 (Fla. 2d DCA June 23, 2006) (Will and Trust Contests)
26. Meyer v. Meyer, __ So.2d __, 2006 WL 1708155 (Fla. 5th DCA June 23, 2006) (Practice & Procedure)
27. Conseco Ins. Co. v. Clark, 2006 WL 2024401 (M.D.Fla. Jul 17, 2006) (NO. 8:06CV462 T30EAJ) (Contested Guardianship Proceedings)
28. Weinberg v. Weinberg, 2006 WL 2265216, 31 Fla. L. Weekly D2094 (Fla.App. 4 Dist. Aug 09, 2006) (Practice & Procedure)
29. Estate of Gunderson v. School Dist. of Hillsborough County, 2006 WL 2612678 (Fla. 1st DCA Sept. 13, 2006) (Creditors' Claims)
30. In re Estate of Cadgene, 2006 WL 2739334 (Fla. 2d DCA Sep 27, 2006) (Creditors' Claims)
31. Bush v. Webb, 2006 WL 2872522 (Fla. 1st DCA October 11, 2006) (Creditors' Claims)
32. In re Estate of Stisser, 932 So.2d 400, 31 Fla. L. Weekly D1008 (Fla. 2d DCA Apr 07, 2006) (Practice & Procedure)
33. Aronson v. Aronson, 930 So.2d 766, 31 Fla. L. Weekly D1317 (Fla. 3d DCA May 10, 2006) (Practice & Procedure)
34. Fleck-Rubin v. Fleck, 933 So.2d 38, 31 Fla. L. Weekly D1369 (Fla. 2d DCA May 12, 2006) (Will and Trust Contests)
35. Pierre v. Estate of Pierre, 928 So.2d 1252, 31 Fla. L. Weekly D1434 (Fla. 3d DCA May 24, 2006) (Will & Trust Contests)
36. Janien v. Janien, 2006 WL 2956304 (Fla. 4th DCA Oct 18, 2006) (Spousal Elective Share Claims)
37. Pisciotti v. Stephens, 2006 WL 3077750 (Fla.App. 4 Dist. Nov 01, 2006) (Practice & Procedure)
38. Cone v. Anderson, 2006 WL 2986471, 31 Fla. L. Weekly D2621 (Fla. 1st DCA Oct 20, 2006) (Practice & Procedure)
39. Morgan v. Cornell, --- So.2d ----, 2006 WL 2987107, 31 Fla. L. Weekly D2632 (Fla. 2d DCA Oct 20, 2006) (Will Construction Litigation)
40. Hayes v. Guardianship of Thompson, 2006 WL 3228916 (Fla. Nov 09, 2006) (Contested Guardianship Proceedings)
41. Baldwin v. Estate Of Winters, 2006 WL 3299834 (Fla. 4th DCA Nov 15, 2006) (Will and Trust Contests)
42. Rice v. Greene, 2006 WL 3327665 (Fla. 5th DCA Nov 17, 2006) (Practice & Procedure)
43. In re Raborn, --- F.3d ----, 2006 WL 3409104 (11th Cir.(Fla.) Nov 28, 2006) (Will and Trust Contests)
44. Joseph v. Chanin, 940 So.2d 483, 31 Fla. L. Weekly D2470 (Fla. 4th DCA Oct 04, 2006) (Will and Trust Contests)
45. Werner v. Estate of McCloskey, 2006 WL 3613178 (Fla. 1st DCA Dec 13, 2006) (Removal of Personal Representatives and Surcharge)
46. Johnson v. Clark, 2006 WL 3780511 (M.D.Fla. Dec 20, 2006) (Will and Trust Contests)
47. Miami Rescue Mission, Inc. v. Roberts, 943 So.2d 274, 31 Fla. L. Weekly D2979 (Fla. 3d DCA Nov 29, 2006) (Will and Trust Contests)
48. Matsumoto v. American Burial and Cremation Services, Inc., --- So.2d ----, 2006 WL 3733310, 32 Fla. L. Weekly D26 (Fla.App. 2 Dist. Dec 20, 2006) (Practice & Procedure)
49. In re Alexander, 346 B.R. 546, 19 Fla. L. Weekly Fed. B 356 (Bankr.M.D.Fla. Jul 25, 2006) (Homestead)
50. In re Edwards, --- B.R. ----, 2006 WL 3788803 (Bankr.M.D.Fla. Oct 04, 2006) (Homestead)
51. Robinson v. Weiland, 936 So.2d 777 (Fla. 5th DCA Sep 01, 2006) (Newly Discovered Evidence/Fraud on the Court)
52. Kranias v. Tsiogas, 941 So.2d 1173 (Fla. 2d DCA Oct 13, 2006) (Evidence/Privilege)
53. Register v. State, 946 So.2d 50 (Fla. 1st DCA Dec 15, 2006) (Guardianship/Due Process)
54. Marlowe v. Brown, 944 So.2d 1036 (Fla. 4th DCA Aug 02, 2006) (Lateral Thinking)
55. Taylor v. Maness, 941 So.2d 559 (Fla. 3d DCA Nov 15, 2006) (Homestead Deeds)
56. Favreau v. Favreau, 940 So.2d 1188 (Fla. 5th DCA Oct 06, 2006) (Pro Se Litigants)
As reported in this New York Law Journal article, Manhattan law firm Graubard Miller has been hit with a suit claiming some of its partners tried to extract almost $50 million in "gifts" and unearned fees from a longtime client, the 80-year-old widow of one of New York City's largest real estate developers, Sylvan Lawrence, who died in 1981. Mr. Lawrence's estate has been embroiled in litigation ever since. Mark Zauderer of DLA Piper Rudnick Gray Cary, who represents Graubard Miller, said Ms. Lawrence's suit against the firm is aimed at avoiding paying a "well-earned fee." Ms. Lawrence, who is represented by Leslie D. Corwin of Greenberg Traurig, is seeking rescission of her retainer agreement and the return of all fees previously paid to the firm and all gifts paid to the partners. The complaint also requests punitive damages and attorney fees.
Scott v. Reyes, 2005 WL 2172231 (Fla. 2d DCA September 9, 2005) (Trial Court Affirmed)
A little-known "exception" to F.S. § 733.702, the statute of limitations applicable to creditor claims against an estate, is the so-called "trust exception" or "equitable title to specifically identifiable property exception." In this case the Second District Court of Appeal provided the following summary of just what the "trust exception" is and when it applies:
Considering the changes to prior law effected by the adoption of the Code and the new statutory language concerning the filing of claims, we summarized the current state of the law relative to the trust exception as follows:
[T]he "trust exception" or "equitable title to specifically identifiable property" exception to the requirements of the nonclaim statute, as those exceptions pertain to recovery of property from an estate, have effectively been limited to those situations where the decedent clearly held the property on behalf of the actual owner either by way of an express trust or some other clearly defined means. In other words, if a decedent asserted beneficial ownership of the property before his death, a claim to the property would be barred unless filed according to section 733.702. The reason being that the dispute as to ownership, creating the cause of action, arose before the decedent's death because the decedent, prior to his death, adversely claimed the property as his own. If, however, the decedent was merely in possession of the property but made no such assertion of ownership prior to his or her death, the assertion of ownership being made by the personal representative or heirs for the first time after the decedent's death would not require the filing of a claim.
In addition to an express trust, the Second District Court of Appeal provided the following additional "candidates" for when the "trust exception" might apply: "a trust imposed by statute . . ., a bailment, and a lease of personal property."
Legal disputes over inherited property are making headlines [locally and] . . . nationwide in the case of Anna Nicole Smith, a former Playmate of the Year. But the millions at stake in these high-profile lawsuits pale in comparison to the trillions of dollars of wealth that will be bequested, inherited and fought over in the next 50 years. As in-court arguments over inherited wealth become more common, law firms are strengthening their trust-and-estate litigation services to meet the demand.
* * * * *
The perfect stormThe reasons for the flurry of trust-and estate-related legal battles are many.
According to an article in the Dispute Resolution Journal, an estimated $41 trillion of wealth will be transferred in the United States from the “Greatest Generation” to their kids, the baby boomers, between 1998 and 2052 [click here]. The massive transfer in wealth alone is enough to spur more family feuds . . .* * * * *
Some lawyers say baby boomers seem much more willing to air their family problems in court than their parents were. Well-publicized trials also contribute to the rise in demand for estate litigation.
McKean v. Warburton, 2005 WL 2155180 (Fla. September 8, 2005) (4th DCA Reversed)
REVISED OPINION: McKean v. Warburton, 2005 WL 3601898 (Fla. September 8, 2005)
The Florida Supreme Court reversed this Fourth DCA decision permitting the distribution of freely devisable homestead property to satisfy a preresiduary bequest. For the reasons discussed here, I think the Florida Supreme Court got this one wrong, turning what should be a benefit, i.e., Florida's homestead protection laws, into one very big trap for the unwary.
In light of skyrocketing real estate values in Florida, for most Florida homeowners, their single most valuable asset is their home. If a homeowner is survived by a spouse or minor children, his or her residence is protected homestead property under Florida's Constitution (Art. X, § 4(c)) and Probate Code (F.S. § 731.201(29)), and thus not subject to devise pursuant to F.S. § 732.4015. However, if the homeowner's residence is NOT protected homestead property, one might be forgiven for assuming that the residence was "freely" devisable.
Not so fast says the Florida Supreme Court. If a homeowner that expects NOT to be survived by a spouse or minor children wants to make sure that his or her single most valuable asset at death can be used to satisfy pre-residuary bequests, the Florida Supreme Court's holding in this case will require that the homeowner specifically provide in his or her Will that the homestead property be sold and added to the general probate estate. Specifically, the Florida Supreme Court summed up its holding in this case as follows:
We therefore . . . hold that where a decedent is not survived by a spouse or minor children, the decedent's homestead property passes to the residuary devisees, not the general devisees, unless there is a specific testamentary disposition ordering the property to be sold and the proceeds made a part of the general estate.
The following appellate briefs were filed with the Florida Supreme Court for this case:
Miami Attorney Jack A. Falk, Jr., Chair of the Probate and Trust Litigation Committee of the Florida Bar, distributed this agenda as well as this memorandum in connection with the following pending and proposed legislative initiatives discussed at the August 18, 2005 litigation committee meeting:
Karasek v. William J. Lamping Trust, 2005 WL 2086183 (Fla. 4th DCA August 31, 2005) (Trial Court Reversed)
Precise drafting is the single most effective barrier against costly probate litigation. What makes estate planning documents especially challenging for attorneys is that the careful drafter needs to consider the very real possibility that the Will or Trust he or she drafts today could become a disputed matter decades in the future (or even hundreds of years in the future under Florida's new rule against perpetuities statute, see F.S. § 689.225). That's what happened in this case. A Will that was executed in 1967 became the subject of litigation in 2003 . . . 36 years after the date it was signed!
The 1967 Will contained a "default" clause common to any well drafted Will. Essentially, the document directed that in the event the testator's children predeceased his surviving spouse, upon the death of his surviving spouse the trust corpus was to be distributed to the "heirs" of his deceased children. What was unclear was whether the 1967 definition of heirs was applicable or the 2003 definition of heirs was applicable. The Fourth District Court of Appeals ruled that under Florida law the presumption is that the testator intended the term "heirs at law" to be construed under the statutes in existence at the time the Will was executed, i.e., 1967.
The entire dispute could have been avoided if the default clause had stated what law was applicable, as the following example does:
If any property is subject to this article under another provision of this Trust Agreement, the Trustee shall distribute that property to my heirs at law determined under Florida law then in effect as if I had died intestate and unmarried on that date as a resident of Florida.
Longmire v. Estate of Ruffin, 2005 WL 2016944 (Fla. 4th DCA August 24, 2005) (Trial Court Reversed)
This Fourth District Court of Appeals opinion should make clear once and for all that if a personal representative should reasonably expect that the estate will be sued by a particular party, F.S. § 733.2121(3)(a) requires that the personal representative treat that potential plaintiff like a creditor entitled to actual notice that the probate proceedings are pending. Although this case involved a personal injury cause of action, there is no reason to believe the applicable rule would be different with respect to any other type of cause of action. Lesson learned: if a personal representative wants to take full advantage of the liability shield created by F.S. § 733.702(1), potential plaintiffs must receive actual notice that the probate proceedings are pending.
Mediated settlement agreements are the norm in Florida when in comes to probate litigation. An excellent resource for thoughtful articles on why probate mediation has "taken off" over the last decade can be found here on the Mediate.com website. But just when you thought mediation was the answer to all of your problems, this interesting post on the Wills, Trusts & Estates Prof Blog (which is reproduced below) discusses yet another option for the creative probate attorney: civil disengagement.
In a recent newsletter, Gerald Le Van, a strong proponent of family wealth mediation, introduces the concept of "civil disengagement" as an alternative to financially and emotionally costly litigation when family members cannot reach an amiable solution.
Mr. Le Van explains that civil disengagement:
- acknowledges current irreconcilable differences,
- but avoids family litigation;
- manages each divided camp separately,
- but leaves the door open to family reunification in later generations.
See Gerald Le Van, Divided Families: Civil Disengagement Instead of War (Aug. 2005).
If all goes according to plan, Florida will soon be adopting its version of the Uniform Trust Code ("UTC"). The following e-mail announcements were circulated to Miami-Dade County probate attorneys on the "proguard" list service. Attached to the announcements was this draft version of the Florida UTC.
August 30, 2005Judge Korvick,
Thanks for getting the word out about the new proposed trust code. I am attaching the latest version. This product will have further revisions before it is filed with the legislature for the 2006 session.
August 29, 2005
Dear friends,
Attached, for your information, is the proposed revision to the Florida Trust Code. Many of you had asked me to please send you this document via e-mail. On August 20, 2005, at the last meeting of The Executive Council of the Real Property, Probate and Trust Law Section of the Florida Bar, The Executive Council unanimously agreed to bring this complete re-draft of the Trust Statutes before the Legislature. This bill already has legislative sponsors. The section also unanimously decided to obtain the assistance of the section's lobbyist, Pete Dunbar, to assist in the passing of this bill.
Brian Felcoski, heading the Trust Committee has done a beautiful job. The proposed bill is drafted, for the most part, adopting the New Uniform Trust Code. The Uniform Trust Code was analyzed and compared to Florida Law by attorneys from around the State. The Uniform Trust Code was annotated by the group so that everyone could see whether there were any major changes to Florida Law.
The new, proposed Florida Trust Code is patterned, in its format, after the Uniform Trust Code. The new Florida Trust Code retains parts of Florida law, not included in the Uniform Trust Code.Sincerely,
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