Ann Christine Bartek v. John Losapio, Jr.

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 7, 2025
DocketA-3022-21
StatusUnpublished

This text of Ann Christine Bartek v. John Losapio, Jr. (Ann Christine Bartek v. John Losapio, Jr.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ann Christine Bartek v. John Losapio, Jr., (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3022-21

ANN CHRISTINE BARTEK,

Plaintiff-Respondent,

v.

JOHN LoSAPIO, JR., Individually, and as Executor of the ESTATE OF JOHN LoSAPIO, SR., DECEASED, and 108 NORTH STREET LLC, a New Jersey limited liability company,

Defendants-Appellants. __________________________

Submitted January 10, 2024 – Decided January 7, 2025

Before Judges Gummer and Walcott-Henderson.

On appeal from the Superior Court of New Jersey, Chancery Division, Morris County, Docket No. P- 002484-16.

Trautmann & Associates, LLC, attorneys for appellants (Gregg D. Trautmann, on the briefs). Smith & Gaynor, LLC, attorneys for respondents (Thomas J. Gaynor, on the brief).

The opinion of the court was delivered by

WALCOTT-HENDERSON, J.S.C. (temporarily assigned).

Defendants John LoSapio, Jr. (Junior), sued in his individual capacity and

as executor of the estate of his father, John LoSapio, Sr.'s (Senior), and 108

North Street LLC appeal from the Chancery Division's April 25, 2022 judgment

in favor of plaintiff Ann Christine Bartek, in which the court, after conducting

a bench trial, ordered that a copy of a January 14, 2016 codicil to the February

6, 2003 last will and testament of Senior, be admitted to probate and that the

title to the remainder interest of property located at 108 North Street in Madison

be "reconveyed."

Plaintiff, who was Senior's sister, had conveyed certain properties,

including her residence in Madison, New Jersey at 108 North Street (the

Madison Property), to Senior subject to a life estate retained by her. 1 According

to plaintiff, Senior in January 2016 had executed a second codicil to his will at

1 We were advised plaintiff passed away on December 24, 2023, during this litigation. The record does not disclose whether a motion for leave to file and serve an amended complaint was ever made to permit an Administrator Ad Prosequendum to pursue the action on behalf of plaintiff's estate. Pursuant to Rule 4:34-1(a), in the event of the death of a plaintiff, "the action does not abate." A-3022-21 2 her request, stating those properties would be conveyed to the living residuary

beneficiaries in plaintiff's last will and testament if Senior predeceased plaintiff.

At the time of Senior's death, however, the 2016 codicil, was not admitted to

probate along with Senior's will. Instead, Junior attested that no codicil existed.

Thus, the remainder interest in the Madison Property was conveyed to Junior

and 108 North Street LLC under Senior's will.

Plaintiff filed suit in the Chancery Division against defendants seeking a

judgment directing, among other things, that a copy of the 2016 codicil be

admitted to probate and the remainder interest in the Madison Property be

reconveyed by defendants to the living residuary beneficiaries in plaintiff's will.

Following a three-day bench trial, the court entered a final judgment in favor of

plaintiff, ordering the codicil to be admitted to probate and title in the Madison

Property be reconveyed. Defendants now appeal, contending the court erred in

admitting a copy of the codicil to probate. For the following reasons, we affirm.

I.

The relevant facts are derived from the trial record and are substantially

undisputed by the parties. In the late 1970s, plaintiff and her husband purchased

the Madison Property and a property in Dover, New Jersey (the Dover Property).

Plaintiff had resided on the Madison Property since 1978. Following the death

A-3022-21 3 of her husband in 2004, however, plaintiff became concerned with her financial

security as she suffered from several medical conditions and feared her estate

would be "wiped out with the cost of [her] long-term care."

Plaintiff sought estate-planning and asset-preservation services from

Donald McHugh, an elder-law attorney. She first met with McHugh in 2005.

Senior, with whom plaintiff "got along very well," accompanied plaintiff to her

meeting with McHugh. At that meeting, McHugh explained there were certain

techniques that would allow her to "qualify for Medicaid services ."2 In that

regard, McHugh advised that it was standard practice for an individual to

transfer the title of real property to a son or daughter who would inherit that

2 To be eligible for Medicaid in New Jersey, an applicant must generally have $2,000 or less in resources. N.J.A.C. 10:71-4.5(c). ("[P]articipation in the program shall be denied or terminated if the total value of an individual's resources exceeds $2,000."). Resources include "any real or personal property which is owned by the applicant . . . and which could be converted to cash to be used for his or her support and maintenance." N.J.A.C. 10:71-4.1(b). If an applicant has disposed of assets within five years of applying for Medicaid or becoming institutionalized in certain facilities, the individual is ineligible for Medicaid's institutional level benefits. N.J.A.C. 10:71-4.10(a). The transfer of an asset for less than fair market value during the look-back period raises a rebuttable presumption that the asset was transferred for the purpose of establishing Medicaid eligibility. H.K. v. Dep't of Hum. Servs., 184 N.J. 367, 380 (2005) (citing N.J.A.C. 10:71-4.10(j)); see also 42 U.S.C. § 1396p(c)(1). To rebut that presumption, the applicant must present "convincing evidence that the assets were transferred exclusively (that is, solely) for some other purpose." N.J.A.C. 10:71-4.10(j). A-3022-21 4 property upon the individual's death while retaining a life estate in the property,

thereby enabling the individual to continue residing at the property and to ensure

the property would not be used to pay for medical expenses. Because plaintiff

did not have any children, McHugh suggested plaintiff transfer the title to the

Madison Property and Dover Property to a "trusted individual."

Plaintiff did not decide anything regarding her estate at that initial meeting

with McHugh. Instead, she discussed her options with Senior. According to

plaintiff, Senior agreed, subject to certain conditions imposed by plaintiff, to

serve as plaintiff's "trusted individual" such that the title to the properties would

be conveyed to him subject to the life estate retained by plaintiff. Those

conditions were that (1) Senior would reconvey the properties back to plaintiff

at any time plaintiff desired; (2) Senior would own the properties if she

predeceased him; and (3) the residuary beneficiaries in plaintiff's will would

own the properties if Senior predeceased plaintiff.

Plaintiff and Senior informed McHugh of this agreement. To effectuate

the agreement, McHugh prepared a supplemental needs trust agreement, two

deeds, and a codicil to Senior's will. The trust agreement was executed in March

2005 and listed plaintiff as the beneficiary and Senior as a trustee. The deeds

A-3022-21 5 were executed on December 12, 2005, and transferred the properties to Senior

subject to plaintiff's life estate.

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