Wills, Trusts & Estates Prof Blog

Article Comparing Jewish and American Inheritance Systems

Donna Litman (Professor of Law, Nova Southeastern University, Shepard Broad Law Center)  & Steven H. Resnicoff (Professor of Law, DePaul University)  recently published an article entitled, Jewish and American Inheritance Law: Commonalities, Clashes, and Estate Planning Consequences, (August 1, 2012). Provided below is the abstract from SSRN:

Jewish inheritance law and American inheritance law share significant similarities. Each prescribes specific distributive rules for those who die intestate and each permits a person the autonomy to elect different distributive rules through a variety of estate planning vehicles. At the same time, each imposes parameters – obligatory in the case of American law and largely hortatory in the case of Jewish law – on the exercise of such autonomy.

In America, the Jewish and secular legal systems can interact with, or contradict, each other in ways that produce unanticipated and undesired results. As a result, effective estate planning requires Jews, and the legal and financial professionals who advise them, to acquire a working knowledge of both the Jewish and American rules. This article provides this background by exploring Jewish inheritance law not only through the lens of comparative law but also from an estate planning perspective, particularly, but not exclusively, with respect to planning for spouses and children.

This article discusses a number of planning options. Depending on the circumstances of a specific case, practical considerations may recommend one technique over another. Nevertheless, Jewish law authorities disagree as to the efficacy of the various alternatives. Therefore, in order to best advise a given client, it may be necessary, with the client’s consent, to consult with the particular religious authorities upon whom the client and his or her intended beneficiaries.

Court Seeks To Remove A Fiduciary Suspected of Evidence Tampering

In Connecticut, a probate judge wants to remove Candace Bednarz from being the fiduciary in her murdered mother’s estate. The court has already ruled payments to creditors are the only distributions to be made out of the estate. The judge recently found out that Bednarz was arrested by police her for tampering with evidence in her mothers murder prosecution. Brett Bednarz, Candace’s brother, has pending charges against him for killing his mother, Beverly Therrien.

Therrien’s most recent will has not been found and her 2006 will was deemed invalid. As a result, state law specified her children as her heirs. The 2006 will cut Candace Bednarz from receiving any estate assets. However, Candace Bednarz petitioned the court to control the estate's assets claiming the entire estate only held $35,000 dollars. According to her arrest warrant, she has withdrawn well over $90,000 dollars in cash. 

See David Owens, East Hartford Probate Judge Seeks To Remove Candace Bednarz From Contorl Of Mother's Estate, Courant.com, Apr. 30, 2013.

Nigerian Supreme Court Upholds Bini Succession Law

The Supreme Court of Nigeria affirmed a custom known as the Bini Law of Succession in Nigeria. Under this succession law, "the first son inherits his father's place of abode (Igiogbe)." The challenge came from Edward Omorodion Uwaifo, who was seeking to set aside his father's entire will. As the first son, Edward was suppose to inherit the Igiogbe; however, his father's will gave the Igiogbe to someone else. The court ruled against the son in part but re-affirmed the customary tradition of the Bini Law of Succession by commenting that it was against Bini customary law to disinherit Edward. Justice Suleiman Galadima held that while the portion of the will that violated Bini could be set aside, the other portions in the will could be salvaged. At issue here was Pa Daniel Ediagbonya Uwaifo's house in Benin City. 

See Adelanwa Bamgboye, Atika Balal, & John Chuks Azu, Nigeria: Supreme Court Re-Affirms Bini Succession Law, allAfrica: Daily Trust, Apr. 23, 2013.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

Judge Approves Thibeault Settlement Agreement

As I have previously discussed, the heirs of Thibeault came to a settlement agreement before the court could hear whether their allegations against the former executor of the estate were determined to be true. All that was left was the judge's approval. On March 11, 2013, "Judge Peter Rosinski signed an order accepting Kelly's accounting of the estate and discharging Kelly of all further responsibilities."

The terms of the settlement agreement that was reached are confidential. While the terms of the settlement agreement are confidential we can assume that Kelly will likely be forced to pay more into the estate than he has already paid back. Unfortunately, it hard to see that justice has been done for the heirs of Thibeault's estate. After all, the heirs were delayed in receiving their inheritances for eights years. Two heirs have passed away during the estate dispute and will never receive their share. The others might have been able to make better use of their inheritance eight years ago.

See Tim Bousquet, Judge Approves Settlement Between Thibeault Heirs and Peter Kelly, The Coast, Mar. 11, 2013.

Widow Gives Up Her Adopted Daughter and Cuts Her Out of the Estate

Christine Svennigsen, a wealthy widow from New York, adopted two Chinese babies. After their adoption, she attempted to place her adopted children up for re-adoption unsuccessfully. Now, Svenningsen has tried to cut her adopted daughter, Emily, out of her estate. Following the death of Svenningsen's husband, she sent her then 8-year-old adopted daughter "to live with another family and tried to cut her out of her out of the family's $250 million estate." The state appeals court rejected her attempts. The court ruled that Emily does deserve a portion of the estate. The son she adopted was re-adopted by another couple soon after she adopted him. Svennigsen claimed that the reason that she placed her adopted children up for adoption was because she could not handle more children. 

Now allegations have emerged that state that Svenningsen used "Draconian" techniques to disclipine her daughter. For example, she used to force her daughter to sleep in a tent if she broke the house rules and that she had behavioral issues. Emily's new mother, however, countered stating that there is no evidence that Emily had any behavior problems.

See Ashley Lutz, Wealthy Widow Tried Unsuccessfully To Cut Adopted Chinese Daughter Out of Her Estate, Business Insider, Mar. 4, 2013.

Special thanks to Laura Galvan (attorney, San Antonio, Texas) and to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

The Importance of Estate Planning for Blended Families

As I have previously discussed, recent publications are providing guidance to plan for the future of a blended family. Over half of all marriages end in divorce, and over 75% of the individuals leaving a broken marriage get remarried. Often times this creates a unique family with stepchildren, and multiple grandparents. It is wise to plan for the unique circumstances of your own family. Not doing so can result in assets being distributed according to the law.

The problem is the law could directly conflict with the preferences of the individual leaving the assets. It is a better to consider drafting a will in writing that outlines who gets what. Oversimplification of a will could lead to someone being disinherited. Another potential problem is what happens to the family home. However, there are legal mechanisms such as a qualified terminable interest property trust that may help get more equitable results. Under a terminable interest property trust, the spouse has a life estate in the property, but the property is transferred to the children after the spouse's death. Later marriages may be more cognizant of the property each partner brought to the union. Ultimately, the creation of a blended family can create unique circumstances. In order to avoid any harmful surprises it is wise to consult with a certified elder law attorney. 

See Bernard Krooks, Plan Estate Carefully for Blended Family, Poughkeepsie Journal, Feb. 23, 2013.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

Reclusive Man Leaves His Estate To Actors He Never Met

Ray Fulk of Illinois had no friends or family left at the time that he died and so when it came time to write his will he decided to leave $5,000 to his favorite charity and the remainder to his two favorite actors. In the end, he left $1,000,000 to Kevin Brophy and Peter Barton. Fulk was a reclusive who lived on a farm. He was so isolated that he would often bathe in a creek when he had no water during the winter. He was not married and had no children or other close relatives. Based upon Illinois intestacy law, Fulk's estate would have likely gone to relatives that he did not know. Fulk wanted to ensure that that would not happen so he wrote a will "leaving $5,000 to the Anti-Cruelty Society in Chicago and the rest to these two strangers, whom he called 'my friends.'"

See Stephanie Moll and Alan Singer, Recluse Leaves Estate To Actors, Bryan Cave: Live, Death and Taxes, Feb. 21, 2013.

Happy Belated-Birthday to President Abraham Lincoln

A Happy Belated-Birthday to the great emancipator and the President who led us through one of the greatest crisis that this nation has faced, the American Civil War. As you already know, President Lincoln was assassinated by John Wilkes Booth at Ford's Theatre. What you may not know was that Lincoln died intestate. This is a brief summary of what happened to his estate after his death. 

It was his son Robert who took it upon himself to ask Justice David Davis, Associate Justice of the Supreme Court of the United States, to become the administrator of his father's estate. Upon his arrival, Robert and Mary Todd Lincoln "wrote a letter to the Judge of the Sangamon County Court, in Illinois, and asked that he appoint Davis as the administrator of Lincoln's Estate." In his initial report, Davis valued the estate at about $85,000. This may not seem like much but his estate would be worth millions of dollars by today's standards. At the time (as it is now) it would be strange to pass that much money without a will, especially for an attorney. The estate finally settled two years later and was valued at $110,296.80. This amount was divided into three equal shares among his widow and his two surviving sons. Mary Todd declined an additional cash allowance that she was entitled to as the surviving spouse. As for Justice Davis, he was never compensated for his work and did not seek reimbursement for his administrative duties, which he handled largely on his own. This is strange because it was customary to at least hire an attorney to take of the administrative duties.

See Danielle & Andrew Mayoras, Are You Better Prepared Than Abraham Lincoln Was?, Forbes, Dec. 4, 2012. 

Inheritance For the Royal Baby

While we do not even know whether Duke and Duchess of Cambridge's baby will be a boy or a girl, their child is already set to inherit a vast fortune and "become the custodian of extraordinarily valuable state assets." Her large inheritance is the result Queen Elizabeth II's great personal wealth. Her majority owns a large number of properties in northwest England known as the Duchy of Lancaster. The Duchy of Lancaster is 46,000 acres collection of property valued at 348 million pounds. The property yields a decent profit at about 13 million pounds per year. King Edward III established the Duchy for his son, Prince John of Gaunt. The duchy was created after Prince John married the Duke of Lancaster's daughter. The couple's son would eventually rise to throne as King Henry IV. It was Henry who decided that the Duchy should remain separate from other crown properties. He also decided that the property would pass directly from the monarch to his or her heirs.

The only thing that could possibly make this better is that the Duchy is tax-free because of 1993 agreement with Queen Elizabeth II and Prime Minister John Major that exempts the assets from the applicable inheritance tax. This would likely also apply to other assets that Queen Elizabeth has received from her father. These properties are a little different than the Duchy because the Duchy's principal must be kept in the principal.  The future heir will also get access to all of the royal palaces. The only trade off here is that the future monarch who inherits will have to manage the crown properties.

See Carolyn Harris, How An Inheritance Awaits Kate and William's Baby?, Bloomberg, Jan. 30, 2013.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

Samsung Chairman Wins Inheritance Against His Siblings

Seoul Central District Court recently held that Samsung Electronics Chairman Lee Kun-hee should inherit control of Samsung against his siblings. Both Kun-hee's older brother and sister, Maeng-hee and Sook-hee, claimed their brother should return 8.24 million shares to the insurer, Samsung Life Insurance. The court stated that while the Chairman's siblings should have actually inherited the stocks at issue the 10-year period to claim the inheritance had already expired. 

See Xinhua, Samsung Chairman Wins Inheritance Lawsuit, China.org: Top News, Feb. 1, 2013.

Nickel From 1913 Will Likely Go For Millions

In Virginia, a rare nickel will likely earn more than $2 million for its owners. The coin apparently has an interesting past. The coin was minted in 1912 and illegally cast in 1913.  The coin was reportedly the product a man named Samuel W. Brown. Brown reportedly altered the dye for the five coins to add a false date. It was discovered in a car accident in 1962 that took the life of its owner,  George O. Walton. Walton was a coin collector and he purchased the coin in 1942 for less than than $4,000. Upon its discovery, one of Walton's heirs Melva Givens inherited the coin, coin collectors informed Givens that they believed that the coin was a fake. It was then forgotten for 30 years because Givens placed in the closet thinking that the coin was worthless.

The current coins owners are four siblings from Virginia, the children of Melva Givens. Since the American Numismatic Association World's Fair of Money determined the identity of the coin, the Waltons donated the coin to the Colorado Springs Museum, who placed the coin on exhibit.

See Steve Skzotak, Nickel From 1913 Likely To Fetch Millions At Auction, ABC, Jan. 31, 2013.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

Effects of Prenuptial Agreements on Long-Term Care

With the rise in second marriages, the use of prenuptial agreements has also increased. The use of prenuptial agreements can have a number of effects on long-term estate planning especially when it comes to the right of election and its affects on Medicaid eligibility. 

Generally speaking, "a surviving spouse's right of election can be exercised whether or not the decedent left a will." How much a spouse can inherit automatically from the estate depends on the applicable state statute. These right of election laws protect a spouse in the event that the entire estate passes to other people. There are only a few ways that a spouse can successfully waive the spouse's right of election and this is one of them. However, according to New York Law Journal, "people often do not realize that this waiver can be treated as a transfer of property for Medical Assistance (Medicaid) eligibility purposes." Unfortunately, Medicaid rules state that any uncompensated transfers of property could subject the applicant to a penalty, which could well affect the applicant's eligibility. This situation can often produce unfair results for those to choose to elect against their spouse's estate. 

See Ann-Margaret Carrozza, Surprising Effects of Prenuptial Agreements on Long-Term Care, New York Law Journal, Jan. 28, 2013.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

Jazz Legend's Secret Daughter

Louis Armstrong, known as the Father of Jazz, also fathered a daughter that no one knew he had. The discovery came as a bit of shock. While Armstrong was a known womanizer, many believed that he passed away without children. The discovery would come 42 years later when his daughter came forward with letters that Armstrong wrote to her mother. In the letters, Armstrong inadvertently revealed how we kept a second family. 

His daughter, 57-year-old Sharon Preston-Folta, claimed that she came forward with the letters because she wanted to story to be known. While many other sources confirmed that Armstrong died without any children, these letters reveal that he supported Ms. Preston-Folta and her mother for about 16 years. In several of the letters, he promised his mistress, Ms. Preston, that he would continue to support her and their daughter. He even bought them a house and would visit them regularly. Her mother stated that she not want to report her daughter because she felt that Armstrong recognition of her as her daughter was enough. As a result, her mother never came forward when his estate was being probated. Armstrong's widow rejected claims that Armstrong ever fathered children, claiming that the late-jazz legend was not able to father children. Ms. Preston-Folta stated that her parents relationship ended in 1967 because Armstrong refused to marry her mother.

See Jacqui Goddard, Louis Armstrong's Secret Daughter Revealed, 42 Years After His Death, The Telegraph, Dec. 15, 2012.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) and Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

France's New Inheritance Laws

Here is a summary of the new rules that the European Union (EU) instituted this past August. In particular, here is how the rules will apply to French citizens living in the United Kingdom (UK) and how English law will apply to the estates of English citizens living in France.

The new regulations will only apply to transfers made at death by succession. The basic rule for succession is that the law of the country where the deceased has his habitual residence at the time of his or her death applies to the decedent's will, regardless of where the decedent estate is located at the time of his or her death. On the other hand, if a person's property is more closely related to another country then the laws of that particular country will apply. A person can also choose which law will apply, but the person is limited to a choice between the country of their natural origin or their habitual residence. It is important to remember that these succession laws do not apply to tax matters. Tax matters, at least in France, are determined by national law. This law might apply to trusts if it deals with a succession issue. This could become problematic in France. 

There is also an issue that deals with time. For an explanation please visit the website that is provided below. These new regulations will apply to all member of the EU, with the exception being the United Kingdom (UK). The reason is because the UK did not adopt these regulations. A solicitor might want to take note of the following scenarios:

1. An English citizen dies as a resident of France and decides to have English law apply to his or her entire estate. Here, the administration of his estate will be governed by English law.
2. A French citizen dies in England and decides to have French law apply to his estate. Here, a decedent's worldwide movable property and his French property will be governed by French law, while his or her English property will be administered by English law.
3. This could become more complicated if an English citizen dies resident in France and decides that French law should apply to the entire estate. Because the English citizen chose France (his or her habitual residence) his movable assets will be administered under French law. There is conflict of laws under this scenario because in England his assets will be governed by his or her domicile (England). This ambiguity was created because England has chose to not adopt the new regulations. It is not clear whether English law or French law should apply to his movable assets.
4. Finally, where a French citizen dies in England and chooses English law, the person's French assets might be administered under English law instead of French law. 

See David Anderson & Nicole Gallop Mildon, The New Inheritance Laws, Complete France, Dec. 14, 2012.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

Rightful Heir of $7 Million In Gold Coins Declared

As I have previously discussed, a reclusive man in Nevada named Walter Samasko, Jr. was found dead in his home along with $7.4 Million in gold coins and bars. Now, officials in Carson City, Nevada have declared Arlene Magdon as the rightful heir to the gold found in Samasko's garage. City Clerk-recorder Alan Grover stated that it took the county at least a month to determine that Magdon was the rightful owner. Grover's research revealed that Magdon was Samasko's first cousin and his only living relative. Magdon was not the only party that was thought to be the relative of the reclusive Nevada man. Many others came forward claiming to be relatives of Samasko. One of these people who came forward claimed that he only recently remembered that he was related to Samasko. The man claimed that he was a secret agent that had suffered a head injury, rendering him unable to remember that he was related to Samasko. 

A court has set a hearing to occur on December 18, 2012 to certify that Magdon as the legitimate heir. After an $800,000 tax on the gold is deducted from the total amount, Magdon is likely to receive the remainder sometime in 2013.

See Arlene Magdon, Distant Relative Of Dead Reclusive Walter Samasko Jr., Heir To $7 Million Found In Garage, The Huffington Post, Dec. 14, 2012.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

Inheritance Rights In Ireland

If a person dies intestate with a spouse and children, there are three different scenarios that might occur. First, the spouse will inherit the entire estate if the person does not have any children. However, if the person does have children, then the spouse will only inherit two-thirds of the estate. The children will divide the remaining one-third amongst themselves. Naturally, if there is no surviving spouse, the children are set to inherit the entire estate. If a person has a will, the will controls unless certain circumstances are met. A surviving spouse always has right in a share of the testator's estate. If the will chooses to disinherit the surviving spouse, then the spouse can take a legal right share in half of the estate if there are no children or one-third if there are children. All of this equally applies to civil partners. 

If the spouses have a Deed of Separation, their entitlement to a share of the former spouse's estate is forfeited. The court that grants a couple a legal divorce grants an order that removes the rights of the former spouse. The rights of a former spouse are only revoked through these particular methods. The rights of spouses that are not legally separated are completely unaffected. It is also important to note that if a person gets married that revokes a prior will. This also applies to civil partners when they participate in a formal ceremony.

There are also inheritance rights for qualified cohabitants. Under Ireland law, a couple is considered a qualifying cohabitant if the couple has lived together "in an intimate and committed relationship for two years or more if they have children together and five years in all other cases." If a person is a qualifying cohabitant, they can apply with a court for a portion of the estate of their partner.

See John Lynch, Spouses, Civil Partners, Cohabitants and Children - Know Your Inheritance Rights, South Tipp Today, Dec. 11, 2012.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

Wife Learns Husband Divorced Her Eight Years Before His Death

A woman from New York, Vivian Pitt Dowers, learned after the death of her husband, David Dowers, that he unilaterally filed for divorced eight years before his death. The move would ensure that his wife could not receive money from his pension or life insurance payout. Vivian had no idea that David had filed for divorce. She maintained that they lived happily together until his death. She only learned that he had filed for divorce after looking through his belongings. This is when she discovered that he filed for divorce in 2002. In the divorce papers, David filed for an "uncontested" split claiming that Vivian abandoned him over their mutual financial problems. He further claimed that she moved to Canarsie following thier split. He claimed that he had properly served her with the divorce papers at an address in Canarsie. In response to this discovery, Vivian obtained a lawyer fought the divorce. A court ruled that the divorce was fraudulent over the protests of David's children from a previous marriage. 

If the court would have ruled the divorce legal, then the children would have inherited everything from their father's estate, including his life insurance policy and pension money. 

See New York Woman Reportedly Learns Husband Divorced Her Eight Years Before His Death, FoxNews.com, Nov. 19, 2012.

When Biology Outpaces the Law

It is a known fact that reproductive technology has quickly outpaced the law and has created problems with determining who is the legal parent of a child, especially when it comes to posthumous conception. Artificial Insemination has made it possible that many individuals could be the legal parents of children created with the help of this technology. This has become a problem for estate planners because while the states have many laws that define "descendants" and "issues," it is still difficult to determine who would qualify for this status. Adoption, non-marital children, and children born to surrogates are also giving estate planners headaches, even though it is easy for technology to establish parenthood for these individuals.

Another issue that occurs is that the law on this matter is sometimes completely absent. Thankfully the state intestacy laws still exist, which can give estate planners a guide to plan around their state's respective inheritance laws. Thus, it is still important for an estate planning attorney to "specific what constitutes parentage, whether by adoption, within marriage or by artificial reproductive technology" within an estate plan. There are also several things that the estate planning attorney might want to consider when making an estate plan, such as:

• "who owns the reproductive matter after the donor’s death;
• whether the donor maintains control of reproductive matter by contract or whether it’s personal property that can be disposed of by will or trust;
• whether the donor of the reproductive matter contemplated or consented to posthumous use of that matter;
• whether there should be some distinction between posthumously born children who are the product of eggs that were fertilized before death, as opposed to those who were the product of eggs fertilized post-death;
• the marital status of the parents at the time of death;
• the period between the birth in comparison to the death and/or date of distribution;
• whether gifts to descendants should include adult adoptees or just minor children."

See David Shayne and Sarah S. Butters, The Kids Are Fine, but Who Are the Parents?, Wealth Management, Nov. 6, 2012.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

English Woman Cleared of Fraud Charges

Marlene Howes, a woman from Gloucester, was found not guilty of benefits fraud. She was accused of committing fraud for concealing an inheritance that she received from her mother. She cleared of all charges when it was discovered that she only used her inheritance to take of her mother's cats. Her mother, Barbara Sutton, specifically left the inheritance to Howes so that her cats "could have 'the best of everything.'" The Magistrate Judge stated that she was free to go because she was only carrying out the wishes of her mother. 

Upon her mother's death, Ms. Howes sold her mother's house and brought her cats to live with her. She took the funds from the sale of her mother's house and placed them in an account for her cats. Howes also stated that she was unaware that she needed to inform the Department of Work and Pensions. 

See Telegraph Reporters, Woman Who Spent £50,000 on Cats Cleared of Benefits Fraud, The Telegraph, Oct. 9, 2012.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.

The Trial In Huguette Clark Estate Dispute Is Set to Begin

As I have previously discussed, there are a number of controversies surrounding the estate of Huguette Clark. The major dispute here arose from the late heiress' will. Apparently, at the time of her death Clark owned two different wills with two different distribution schemes. In the first will, Clark provided a $5 million gift to the nurse that cared for her, and bequested the vast majority of her estate to remaining living relatives on her father's side. The will stated that the her estate should be given to her "intestate distributees," which means the relatives that would have inherited if Clark did not have a will.

The second will, which was written about 6 weeks following the drafting of the first will, explicitly disinherited a majority of the people that were set to receive an inheritance from the first will. The second will gives most of the money to establish a museum and provides a number of bequests to people who are a part of her life. These people included "her attorney, accountant, doctor, and others, and the remainder is split among the nurse, a goddaughter and the California foundation." 

At the beginning of the trial, her estate is said to be worth about $300 million, not including the unpaid federal gift taxes that the estate still has to pay. As I have previously discussed, the two men who managed her estate were dismissed from their positions. While a criminal investigation was started, neither man has had charges brought against them. With that said, the Elder Abuse Unit of the New York County District Attorney's Office is still investigating the matter.

See Bill Dedman, Up For Grabs: The $300 Million Estate of Reclusive Heiress Huguette Clark, NBC News, Oct. 5, 2012.

Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) and Jim Hillhouse(Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.