Estate of Frances C. Glover, a.k.a. Frances C. Cloud, Deceased, Kevin Holleran and Wilmington Trust Co., Administrators Pro Tem - Page 8




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               At an unspecified date in 1987, Mr. Ross (until his death in           
          1989) and Ms. Hurley began to misappropriate decedent’s funds.  By          
          the date of decedent’s death in 1991, they had misappropriated              
          approximately $1.6 million.  Mr. Ross and Ms. Hurley used these             
          funds to pay their personal expenses and to invest in business              
          ventures.  They retained Eckell, Sparks to represent them in some           
          of these business ventures.                                                 
          Decedent’s Will                                                             
               In June 1989, Mr. Ross and Ms. Hurley engaged Eckell, Sparks           
          to draft a new will (the 1989 will) for decedent.  Before this              
          time, Eckell, Sparks had not performed legal services for decedent.         
          Eckell, Sparks did not send decedent an “engagement letter”                 
          acknowledging their representation of her or specifying the fee             
          arrangement.  Nor did any attorney from Eckell, Sparks meet or              
          communicate with decedent.  Rather, in preparing the 1989 will for          
          decedent, Joseph Monte of Eckell, Sparks used decedent’s prior will         
          (the old will), which was provided by Mr. Ross and Ms. Hurley, and          
          relied upon information provided by Mr. Ross and Ms. Hurley.                
               Decedent had a longtime companion, Edward H. Cloud, whom she           
          married on June 13, 1990.  She also had one brother, Rolfe E.               
          Glover III, who had three children, Rolfe E. Glover IV, Gordon F.           
          Glover, and Katherine C. Glover.  (Reference to Mr. Glover is to            
          Rolfe E. Glover IV, and reference to the Glovers is to the three            








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